## State of Utah

Department of Environmental Quality

Dianne R. Nielson, Ph.D.

Executive Director

DIVISION OF AIR QUALITY Richard W. Sprott

Directo r JON M. HUNTSMAN, JR.

Governor

GARY HERBERT

Lieutenant Governor
Site ID: 10303



## Title V Operating Permit

PERMIT NUMBER: 2300015002 DATE OF PERMIT: December 1, 2006 Date of Last Revision: December 1, 2006

This Operating Permit is issued to, and applies to the following:

Name of Permittee:

Ash Grove Cement Company

PO Box 51 Nephi, UT 84648 Permitted Location:

Leamington Cement Plant Hwy 132 Leamington, UT 84638

UTM coordinates: 4,379,850 meters No rthing, 397,300 meters Easting

SIC code: 3241



## ABSTRACT

Ash Grove Cement Company operates the Leamington cement manufacturing plant in Juab County, Utah. This plant has been in operation since 1981. At th e Leamington cement plant, cement is produced when inorganic raw materials, primarily limestone (quarri ed on site), are correctly proportioned, ground and mixed, and then fed into a rotating kiln. The kiln alters the materials and recombines them into small

stones called cement clinker. The clinker is cool ed and ground with gypsum and additional limestone into a fine powdered cement. The final product is stor ed on site for later shipping. The major sources of

air emissions are from the combustion of fuels for th e kiln operation, from the kiln, and from the clinker cooling process. The Leamington cement plant is a major source for emissions of PM 10 , NO

x , and CO, and is subject to NSPS Subparts A, Y, & OOO, and NESHAP Subparts A & LLL.

UTAH AIR QUALITY BOARD

By: Prepared By:

Richard W. Sprott, Executive Secretary Brandy Cannon

150 North 1950 West • PO Box 144820 • Salt Lake City, UT 84114-4820 • phone (801) 536-4000 • fax (801) 536-4099

T.D.D. (801) 536-4414 • www.deq.utah.gov

## Operating Permit History

1/5/2000 - Permit issued Action initiated by an initial operating permit application

12/24/2003 -Permit modified Action initiated by an

administrative amendment (initiated by source) To add the cross-belt analyzer approved in DAQE-AN0303009-03 and incorporate limit changes from DAQE-AN0303006-03. In addition, a number of small changes or

corrections were made. These result from minor changes in previously listed equipment and to correct typographical errors.

7/29/2005 -Permit modified Action initiated by an

administrative amendment (initiated by DAQ) To incorporate changes approved in DAQE-AN0303011-05, dated May 20, 2005, including the following: installation of a limestone bypass system to incorporate additional limestone into the clinker and gypsum prior to the finish mill, addition of two new baghouses associated with the limestone bypass system located at the new limestone silo and conveyor, and replacement of two baghouses (419.BF4, 419.BF5) controlling discharge from the east and west clinker belts into the clinker storage silos. Additional permit changes include: correction of typographical errors, update of emission unit identification numbers, and revision of the SSMP and O&M plan conditions to more closely reflect MACT language.

12/1/2006 - Permit issued Action initiated by a renewal of an operating permit

## Table of Contents

SECTION I: GENERAL PROVISIONS .................................................................................................. 1

I.A. F EDERAL E NFORCEMENT ..............................................................................................................1

I.B. P ERMITTED A CTIVITY ( IES ). ..........................................................................................................1

I.C. D UTY TO C OMPLY . .......................................................................................................................1

I.D. P ERMIT E XPIRATION AND R ENEWAL ............................................................................................2

I.E. A PPLICATION S HIELD . ..................................................................................................................2

I.F. S EVERABILITY . .............................................................................................................................2

I.G. P ERMIT F EE ...................................................................................................................................2

I.H. N O P ROPERTY R IGHTS ..................................................................................................................2

I.I. R EVISION E XCEPTION . ..................................................................................................................2

I.J. I NSPECTION AND E NTRY ...............................................................................................................2

I.K. C ERTIFICATION . ............................................................................................................................3

I.L. C OMPLIANCE C ERTIFICATION .......................................................................................................3

I.M. P ERMIT S HIELD .............................................................................................................................4

I.N. E MERGENCY P ROVISION ...............................................................................................................4

I.O. O PERATIONAL F LEXIBILITY ..........................................................................................................5

I.P. O FF

- PERMIT C HANGES ..................................................................................................................5 I.Q. A DMINISTRATIVE P ERMIT A MENDMENTS . ...................................................................................5

I.R. P ERMIT M ODIFICATIONS ...............................................................................................................5

I.S. R ECORDS AND R EPORTING . ..........................................................................................................5

I.T. R EOPENING FOR C AUSE . ...............................................................................................................7

I.U. I NVENTORY R EQUIREMENTS . .......................................................................................................7

SECTION II: SPECIAL PROVISIONS................................................................................................. ..8

II.A. E MISSION U NIT ( S ) P ERMITTED TO D ISCHARGE A IR C ONTAMINANTS ..........................................8

II.B. R EQUIREMENTS AND LIMITATIONS .............................................................................................10

II.B.1 Conditions on permitted source (Source-wide) ............................................................... 10

II.B.2 Conditions on Stationary Crusher (211.BF1) .................................................................. 19

II.B.3 Conditions on Raw Material Transfer (211.BF2) ........................................................... 23

II.B.4 Conditions on Coal Grinding System (41B.BF2) ............................................................ 24

II.B.5 Conditions on Coal Silo (41B.BF1) ................................................................................... 26

II.B.6 Conditions on Kiln & Pre-Calciner and Raw Mill (317.BF1) ........................................ 26

II.B.7 Conditions on Clinker Cooler (419.BF1) ......................................................................... 38

II.B.8 Conditions on Finish Mill (514.BF2) ................................................................................ 41

II.B.9 Conditions on Finish Mill Separator (514.BF1) .............................................................. 44

II.B.10 Conditions on Materials Handling Operation (MHO) ................................................... 48

II.B.11 Conditions on Limestone Bypass System (LBS) .............................................................. 50

II.B.12 Conditions on Belt Conveyor Transfer Baghouse (311.BC1) ......................................... 51

II.C. E MISSIONS T RADING ...................................................................................................................52

II.D. A LTERNATIVE O PERATING S CENARIOS ......................................................................................52

SECTION III: PERMIT SHIELD..................................................................................................... ......52

SECTION IV: ACID RAIN PROVISIONS............................................................................................53Issued under authority of Utah Code Ann. Sect ion 19-2-104 and 19-2-109. 1, and in accordance with Utah Administrative Code R307-415 Operating Permit Requirements.

All definitions, terms and abbreviations used in this permit conform to those used in Utah Administrative Code R307-101 and R307-415 (Rules), and 40 Code of Federa l Regulations (CFR), except as otherwise defined in this permit. Unl ess noted otherwise, references cited in the permit

conditions refer to the Rules.

Where a permit condition in Section I, General Provisions, partially recites or summarizes an applicable rule, the full text of the applicable por tion of the rule shall govern interpretations of the requirements of the rule. In the case of a conflict between the Rules and the permit terms and conditions of Section II, Special Provisions, the perm it terms and conditions of Section II shall govern except as noted in Provision I.M, Permit Shield.



## Section I: General Provisions

I.A. Federal Enforcement.

All terms and conditions in this permit, including those provisions designed to limit the potential to emit, are enforceable by the EPA and citizen s under the Clean Air Act of 1990 (CAA) except those terms and conditions that are specifically designated as "State Requirements". (R307-415- 6b)

I.B. Permitted Activity(ies).

Except as provided in R307-415-7b(1), the permitt ee may not operate except in compliance with this permit. (See also Provision I.E, Application Shield)

I.C. Duty to Comply.

I.C.1 The permittee must comply with all conditi ons of the operating permit. Any permit noncompliance constitutes a violation of the Air C onservation Act and is grounds for any of the following: enforcement action; permit termination; revocation and reissuance; modification; or denial of a permit renewal a pplication. (R307-415-6a(6)(a))

I.C.2 It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this perm it. (R307-415-6a(6)(b))

I.C.3 The permittee shall furnish to the Executive Secret ary, within a reasonable time, any information that the Executive Secretary may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating this permit or to determine compliance with this permit. Upon request, the permittee shall also furnish to the Execu tive Secretary copies of records required to be kept by this permit or, for information claimed to be confidential, the permittee may furnish such records directly to the EPA along with a claim of confidentiality. (R307-415-6a(6)(e))

I.C.4 This permit may be modified, revoked, reopened, and reissued, or terminated for cause. The filing of a request by the permittee for a permit modification, revocation and reissuance, or termination, or of a notification of planned ch anges or anticipated noncompliance shall not stay any permit condition, except as provided under R307 -415-7f(1) for minor permit modifications. (R307-415-6a(6)(c))

Issued December 1, 2006 Page 1 Title V Operating Permit #2300015002I.D. Permit Expiration and Renewal.

I.D.1 This permit is issued for a fixed term of five years and expires on December 1, 2011 . (R307- 415-6a(2))

I.D.2 Application for renewal of this permit is due by June 1, 2011. An application may be submitted early for any reason. (R307-415-5a(1)(c))

I.D.3 An application for renewal submitted after the due date listed in I.D.2 above shall be accepted for processing, but shall not be considered a timely application and shall not relieve the permittee of any enforcement actions resulting from submitti ng a late application. (R307-415-5a(5))

I.D.4 Permit expiration terminates the permittee's right to operate unless a timely and complete renewal application is submitted consistent with R307-415-7b (see also Prov ision I.E, Application Shield) and R307-415-5a(1)(c) (see also Provision I.D.2). (R307-415-7c(2))

I.E. Application Shield.

If the permittee submits a timely and complete app lication for renewal, the permittee's failure to have an operating permit will not be a violation of R307-415, until the Executive Secretary takes final action on the permit renewal application. In such case, the terms and conditions of this permit shall remain in force until permit renewal or denial. This protection shall cease to apply if, subsequent to the completeness determinati on required pursuant to R307-415-7a(3), and as required by R307-415-5a(2), the applicant fails to submit by the deadline specified in writing by the Executive Secretary any additional informa tion identified as being needed to process the application. (R307-415-7b(2))

I.F. Severability.

In the event of a challenge to any portion of this permit, or if any portion of this permit is held invalid, the remaining permit conditions rema in valid and in force. (R307-415-6a(5))

I.G. Permit Fee.

I.G.1 The permittee shall pay an annual emission fee to the Executive Secretary consistent with R307- 415-9. (R307-415-6a(7))

I.G.2 The emission fee shall be due on October 1 of each calendar year or 45 days after the source receives notice of the amount of the fee, whichever is later. (R307-415-9(4)(a))

I.H. No Property Rights.

This permit does not convey any property rights of any sort, or any exclusive privilege. (R307- 415-6a(6)(d))

I.I. Revision Exception.

No permit revision shall be required, under any approved economic incentives, marketable permits, emissions trading and other similar pr ograms or processes for changes that are provided for in this permit. (R307-415-6a(8))

I.J. Inspection and Entry.

Issued December 1, 2006 Page 2 Title V Operating Permit #2300015002I.J.1 Upon presentation of credentials and other documen ts as may be required by law, the permittee shall allow the Executive Secretary or an aut horized representative to perform any of the following:

I.J.1.a Enter upon the permittee's prem ises where the source is located or emissions related activity is conducted, or where records are kept under the conditions of this permit. (R307-415-6c(2)(a))

I.J.1.b Have access to and copy, at reasonable times, any records that must be kept under the conditions of this perm it. (R307-415-6c(2)(b))

I.J.1.c Inspect at reasonable times any facilities, equipment (including monitoring and air pollution control equipment), practice, or ope ration regulated or required under this permit. (R307-415-6c(2)(c))

I.J.1.d Sample or monitor at reasonable times substances or parameters for the purpose of assuring compliance with this permit or app licable requirements. (R307-415-6c(2)(d))

I.J.2 Any claims of confidentiality made on the information obtained during an inspection shall be made pursuant to Utah Code Ann. Section 19-1-306. (R307-415-6c(2)(e))

I.K. Certification.

Any application form, report, or compliance certif ication submitted pursuant to this permit shall contain certification as to its truth, accuracy, and completeness, by a responsible official as

defined in R307-415-3. This cer tification shall state that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete. (R307-415-5d)

I.L. Compliance Certification.

I.L.1 Permittee shall submit to the Executive Secretar y an annual compliance certification, certifying compliance with the terms and conditions containe d in this permit, including emission limitations, standards, or work practices. This certif ication shall be submitted no later than January 30, 2007 and that date each year following until this permit expires. The certification shall include all the following (permittee may cross-reference this pe rmit or previous repor ts): (R307-415-6c(5))

I.L.1.a The identification of each term or condition of this permit that is the basis of the certification;

I.L.1.b The identification of the methods or other m eans used by the permittee for determining the compliance status with each term and condition during the certification period. Such methods and other means shall include, at a minimum, the monitoring and related recordkeeping and reporting requirements in th is permit. If necessary, the permittee also shall identify any other material information that must be included in the certification to comply with section 113(c)(2) of the Act, which prohibits knowingly making a false certification or omitting material information;

I.L.1.c The status of compliance with the terms a nd conditions of the permit for the period covered by the certification, including whether compliance during the period was

continuous or intermittent. The certificat ion shall be based on the method or means

Issued December 1, 2006 Page 3 Title V Operating Permit #2300015002designated in Provision I.L.1.b. The certifica tion shall identify each deviation and take it into account in the compliance certification. The certification shall also identify as possible exceptions to compliance any peri ods during which compliance is required and in which an excursion or exceedance as defined under 40 CFR Part 64 occurred; and

I.L.1.d Such other facts as the Executive Secretar y may require to determine the compliance

status.

I.L.2 The permittee shall also submit all compliance cer tifications to the EPA, Region VIII, at the following address or to such other address as ma y be required by the Executive Secretary: (R307-415-6c(5)(d))

Office of Enforcement, Compliance and Environmental Justice (Mail code 8ENF) EPA, Region VIII 999 18th Street, Suite 300 Denver, CO 80202-2466

I.M. Permit Shield.

I.M.1 Compliance with the provisions of this permit sh all be deemed compliance with any applicable requirements as of the date of this permit, provided that:

I.M.1.a Such applicable requirements are included and are specifically identified in this permit, or (R307-415-6f(1)(a))

I.M.1.b Those requirements not applicable to the sour ce are specifically identified and listed in this permit. (R307-415-6f(1)(b))

I.M.2 Nothing in this permit shall alter or affect any of the following:

I.M.2.a The emergency provisions of Utah Code Ann. Section 19-1-202 and Section 19-2-112, and the provisions of the CAA Section 303. (R307-415-6f(3)(a))

I.M.2.b The liability of the owner or operator of th e source for any violation of applicable requirements under Utah Code Ann. Section 19-2-107(2)(g) and Section 19-2-110 prior to or at the time of issuance of this permit. (R307-415-6f(3)(b)

I.M.2.c The applicable requirements of the Acid Rain Program, consistent with the CAA Section 408(a). (R307-415-6f(3)(c))

I.M.2.d The ability of the Executive Secretary to obtain information from the source under Utah Code Ann. Section 19-2-120, and the ability of the EPA to obtain information from the source under the CAA Section 114. (R307-415-6f(3)(d))

I.N. Emergency Provision.

I.N.1 An “emergency” is any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, an d that causes the source to exceed a technologyIssued December 1, 2006 Page 4 Title V Operating Permit #2300015002based emission limitation under this permit, due to unavoidable increases in emissions attributable to the emergency. An emergenc y shall not include noncompliance to the extent caused by improperly designed equi pment, lack of preventive maintenance, careless or improper operation, or operator error. (R307-415-6g(1))

I.N.2 An emergency constitutes an affirmative defen se to an action brought for noncompliance with such technology-based emission limitations if the affirmative defense is demonstrated through properly signed, contemporaneous operating logs, or other relevant evidence that:

I.N.2.a An emergency occurred and the permittee can identify the causes of the emergency. (R307-415-6g(3)(a))

I.N.2.b The permitted facility was at the time bei ng properly operated. (R307-415-6g(3)(b))

I.N.2.c During the period of the emergency the permittee took all reasonable steps to minimize

levels of emissions that exceeded the emissi on standards, or other requirements in this permit. (R307-415-6g(3)(c))

I.N.2.d The permittee submitted notice of the emergenc y to the Executive Secretary within two working days of the time when emission limitations were exceeded due to the emergency. This notice must contain a description of the emergency, any steps taken to mitigate emissions, and corrective actions taken. This notice fulfills the requirement of Provision I.S.2.c below. (R307-415-6g(3)(d))

I.N.3 In any enforcement proceeding, the permittee seeking to establish the occurrence of an emergency has the burden of proof. (R307-415-6g(4))

I.N.4 This emergency provision is in addition to any emergency or upset provision contained in any other section of this permit. (R307-415-6g(5))

I.O. Operational Flexibility.

Operational flexibility is governed by R307-415-7d(1).

I.P. Off-permit Changes.

Off-permit changes are governed by R307-415-7d(2).

I.Q. Administrative Permit Amendments.

Administrative permit amendments are governed by R307-415-7e.

I.R. Permit Modifications.

Permit modifications are governed by R307-415-7f.

I.S. Records and Reporting.

I.S.1 Records.

I.S.1.a The records of all required monitoring data a nd support information shall be retained by the permittee for a period of at least five years from the date of the monitoring sample,

Issued December 1, 2006 Page 5 Title V Operating Permit #2300015002measurement, report, or application. Su pport information includes all calibration and maintenance records, all original strip-charts or appropriate recordings for continuous monitoring instrumentation, and copies of all reports required by this permit. (R307-415- 6a(3)(b)(ii)

I.S.1.b For all monitoring requirements described in Section II, Special Provisions, the source shall record the following information, where applicable: (R307-415-6a(3)(b)(i))

I.S.1.b.1 The date, place as defined in this permit, and time of sampling or measurement.

I.S.1.b.2 The date analyses were performed.

I.S.1.b.3 The company or entity that performed the analyses.

I.S.1.b.4 The analytical techniques or methods used.

I.S.1.b.5 The results of such analyses.

I.S.1.b.6 The operating conditions as existing at the time of sampling or measurement.

I.S.1.c Additional record keeping requirements, if any, are described in Section II, Special

Provisions.

I.S.2 Reports.

I.S.2.a Monitoring reports shall be submitted to th e Executive Secretary every six months, or more frequently if specified in Section II. All instances of deviation from permit requirements shall be clearly identified in the reports. (R307-415-6a(3)(c)(i))

I.S.2.b All reports submitted pursuant to Provision I. S.2.a shall be certified by a responsible official in accordance with Provision I.K of this permit. (R307-415-6a(3)(c)(i)

I.S.2.c The Executive Secretary shall be notified promptly of any deviations from permit requirements including those attributable to up set conditions as defined in this permit, the probable cause of such deviations, and any corrective actions or preventative measures

taken. Prompt, as used in this condition, sha ll be defined as written notification within 14 days . Deviations from permit requirements due to unavoidable breakdowns shall be reported in accordance with the provi sions of R307-107. (R307-415-6a(3)(c)(ii))

I.S.3 Notification Addresses.

I.S.3.a All reports, notifications, or other submissions required by this permit to be submitted to the Executive Secretary are to be sent to the following address or to such other address as may be required by the Executive Secretary:

Utah Division of Air Quality

P.O. Box 144820 Salt Lake City, UT 84114-4820

Phone: 801-536-4000

Issued December 1, 2006 Page 6 Title V Operating Permit #2300015002I.S.3.b All reports, notifications or other submissions required by this permit to be submitted to

the EPA should be sent to one of the follow ing addresses or to such other address as may be required by the Executive Secretary:

For annual compliance certifications For reports, notifications, or other correspondence related to permit modifications, applications, etc. Environmental Protection Agency, Region VIII Office of Enforcement, Compliance and Environmental Justice (mail code 8ENF) 999 18th Street, Suite 300 Denver, CO 80202-2466 Environmental Protection Agency, Region VIII Office of Partnerships & Regulatory Assistance Air & Radiation Program (mail code 8P-AR) 999 18th Street, Suite 300 Denver, CO 80202-2466

Phone: 303-312-6440

I.T. Reopening for Cause.

I.T.1 A permit shall be reopened and revised u nder any of the following circumstances:

I.T.1.a New applicable requirements become applicable to the permittee and there is a remaining permit term of three or more years. No such reopening is required if the effective date of the requirement is later than the date on wh ich this permit is due to expire, unless the

terms and conditions of this permit have been extended pursuant to R307-415-7c(3), application shield. (R307-415-7g(1)(a))

I.T.1.b The Executive Secretary or EPA determines that this permit contains a material mistake

or that inaccurate statements were made in establishing the emissions standards or other

terms or conditions of this permit. (R307-415-7g(1)(c))

I.T.1.c EPA or the Executive Secretary determines that this permit must be revised or revoked to assure compliance with applicable requirements. (R307-415-7g(1)(d))

I.T.1.d Additional applicable requirements are to beco me effective before the renewal date of this permit and are in conflict with ex isting permit conditions. (R307-415-7g(1)(e))

I.T.2 Proceedings to reopen and issue a permit sha ll follow the same procedures as apply to initial permit issuance and shall affect only those parts of this permit for which cause to reopen exists. (R307-415-7g(2))

I.U. Inventory Requirements.

Emission inventories shall be submitted in acco rdance with the procedures of R307-150, Emission Inventories. (R307-150)

Issued December 1, 2006 Page 7 Title V Operating Permit #2300015002

## Section II: SPECIAL PROVISIONS

II.A. Emission Unit(s) Permitted to Discharge Air Contaminants.

(R307-415-4(3)(a) and R307-415-4(4))

II.A.1 Quarry Operations (designated as Quarry) Unit Description: Rock drilling operations, truck hauling, and storage piles. No unitspecific applicable requirements.

II.A.2 Stationary Crusher (designated as 211.BF1) Unit Description: Stationary crusher with an approximate production rate of 1,000 tons per hour, for reduction of quarried material to 3 inch minus sized material. The crusher is equipped with a baghouse and with wate r sprays on the feed hopper. (pre-1983)

II.A.3 Raw Material Transfer (designated as 211.BF2) Unit Description: Crushed material is transported to raw material storage by belt B8. The raw material transfers at the end of convey or B8 prior to loading into raw material reclaim area. The conveyor transfer point is equipped with a baghouse & water sprays. (pre-1983)

II.A.4 Raw Material Silos (designated as 315.SX1 thru 4) Unit Description: Raw materials such as limestone , silica, iron, and shale are stored in one of four silos. The four silos are equipped with one common baghouse.

II.A.5 Fifth Component Silo (designated as 315.BF2) Unit Description: Raw materials are stored in a silo. This silo is equipped with a baghouse.

II.A.6 Kiln Feed Blending Silos (2) (designated as 411.BF1 and 2) Unit Description: Raw material is blended in one of two blending silos prior to feeding the kiln. The blending silos are controlled by one common baghouse.

II.A.7 Blending Silo Elevators (2) (designated as 412.BF1 and 2) Unit Description: Blended kiln feed is transferred to the kiln by bucket elevators. The elevators are equipped with a baghouse.

II.A.8 Coal Grinding System (designated as 41B.BF2) Unit Description: Coal is ground in a coal mill. Gases drawn from the preheater for the kiln entrain the coal in the mill and are dedusted in a baghouse.

II.A.9 Coal Silo (designated as 41B.BF1) Unit Description: Storage of coal for grinding to powder, which is subsequently fired in the kiln and calciner. The coal storag e silo is equipped with a baghouse.

II.A.10 Kiln & Pre-Calciner and Raw Mill (designated as 317.BF1) Unit Description: Kiln burning process, calciner, and preheater tower off gases are directed through the bottom of the raw mill wh ere finely ground raw material is picked up. Combustion gases and fine raw materials are then vented to a baghouse.

II.A.11 Raw Mill Recirculation (designated as 316.BF1 thru 5)Unit Description: Larger particles are removed from the raw mill, recirculated, and reintroduced into the raw mill feed. This sy stem includes vibrating feeders, a conveyor system, and surge bin. Emissions are controlled by five equivalent baghouses.

II.A.12 Cross-Belt Analyzer (designated as 316.BF6) Unit Description: Used for quality control. Emissions are controlled by a baghouse.

II.A.13 Kiln Feed Alleviator (designated as 414.BF1) Unit Description: A baghouse controls particul ate from the central material silo between the blending silos and the preheater. Raw f eed is removed from the system near the top of the preheater tower.

Issued December 1, 2006 Page 8 Title V Operating Permit #2300015002II.A.14 Clinker Cooler (designated as 419.BF1) Unit Description: Grate type cooler used for c ooling clinker from the kiln prior to transfer to clinker storage. The clinker cooler vent air is controlled by a baghouse.

II.A.15 Clinker Belt Transfer (designated as 419.BF8) Unit Description: Clinker is removed from the clinker cooler by drag chains and dropped onto one of the clinker conveyor belts. The transfer points are controlled by a baghouse.

II.A.16 East Clinker Belt (designated as 419.BF4) Unit Description: Clinker from the clinker cooler is transferred into the East clinker silo by conveyor belt. The discharge from the belt is controlled by a baghouse.

II.A.17 West Clinker Belt (designated as 419.BF5) Unit Description: Clinker from the clinker cooler is transferred into the West clinker silo by conveyor belt. The discharge from the belt is controlled by a baghouse.

II.A.18 Clinker Silos (designated as 511.BF2 and 3) Unit Description: Clinker from the clinker cooler is transferred to one of three storage silos. Each clinker storage silo is equipp ed with a baghouse to control emissions when loading.

II.A.19 Clinker Reclaim Hopper (designated as 511.BF1) Unit Description: Imported clinker is fed to the clinker tunnel conveyor belt by the outside clinker hopper. Emissions during tr ansfer of clinker to the conveyor are controlled by a baghouse that discharges into the clinker tunnel.

II.A.20 East Clinker Silo Discharge (designated as 511.BF2) Unit Description: Produced clinker is fed to the clinker tunnel conveyor belt from the East clinker storage silo. Emissions during transfer of clinker to the conveyor are controlled by a baghouse that discharges into the clinker tunnel.

II.A.21 West Clinker Silo Discharge (designated as 511.BF3) Unit Description: Produced clinker is fed to the clinker tunnel conveyor belt from the West clinker storage silo. Emissions during transfer of clinker to the conveyor are controlled by a baghouse that discharges into the clinker tunnel.

II.A.22 Gypsum Silo Discharge (designated as 511.BF4) Unit Description: Gypsum is fed to the clinker tunnel conveyor belt from the gypsum storage silo. Emissions during transfer of gypsum to the conveyor are controlled by a baghouse that discharges into the clinker tunnel.

II.A.23 Clinker Tunnel Exitway (designated as 511.BF1 thru 4) Unit Description: The clinker reclaim hoppe r baghouse (511.BF1), east clinker silo baghouse (511.BF2), west clinker silo ba ghouse (511.BF3), and gypsum silo baghouse (511.BF4) all discharge in the clinker tunnel. Emissions are discharged through the tunnel exitway.

II.A.24 Gypsum Silo (designated as 512.SX1) Unit Description: Gypsum is stored in the gypsum storage silo. A baghouse is installed on the gypsum storage silo to control dust during loading.

II.A.25 Finish Mill (designated as 514.BF2) Unit Description: The finish mill grinds clinker and gypsum to produce finished cement product. Dust generated during milling is captured by a baghouse.

II.A.26 Finish Mill Separator (designated as 514.BF1) Unit Description: After clinker and gypsum are ground into cement product, a separator returns the oversized cement particles to the fi nish mill. Dust generated by the finish mill separator is collected by a baghouse.

II.A.27 Finish Cement Storage Silos (designated as 611.BF1) Unit Description: There are six storage and two interstice silos where the finished cement product is stored. A single common baghouse is located on top of the silos and is used to control emissions during load ing and unloading operations.

Issued December 1, 2006 Page 9 Title V Operating Permit #2300015002II.A.28 North Cement Load Out (designated as 611.BF2) Unit Description: The cement loadout system located on the North side of the silos (rail load out side) is controlled by a baghouse during unloading from the silos for rail shipping.

II.A.29 South Cement Load Out (designated as 611.BF3) Unit Description: The cement loadout system located on the South side of the silos (truck load out side) is controlled by a baghouse during unloading from the silos for truck shipping.

II.A.30 Materials Handling Operation (designated as MHO) Unit Description: Includes the following emission units: 315.SX1 thru 4; 315.BF2; 316.BF1 thru 5; 316.BF6; 411.BF1 & 2; 412.BF1 & 2; 414.BF1; 419.BF8; 419.BF4; 419.BF5; 511.BF2 & 3; 511.BF1 thru 4; 512.SX1; 611.BF1; 611.BF2; 611.BF3; 512.BF2

& 3.

II.A.31 Limestone Bypass System (designated as LBS) Unit Description: Additional limestone is added to the clinker and gypsum by the limestone bypass system (LBS). The LBS consists of a screen and conveyors. Emissions are controlled by water sprays at the screen and material handling drop points.

II.A.32 Limestone Silo & Belt (designated as 512.BF2 and 3) Unit Description: Limestone is stored in the lim estone storage silo and transferred to the finish mill by conveyor belt. Emissions from the silo and conveyor are controlled by two baghouses. 512.BF2 discharges in the clinker tunnel. 512.BF3 is located on top of the

silo.

II.A.33 Belt Conveyor Transfer Baghouse (designated as 311.BC1) Unit Description: Located prior to raw ma terials processing, this baghouse controls emissions from the conveyor belt that transfers the stacked material to the raw material

silos.

II.B. Requirements and limitations.

The following emission limitations, standards, and operational limitations apply to the permitted facility as indicated: (R307-415-6a(1))

II.B.1 Conditions on permitted source (Source-wide)

II.B.1.a Condition:

At all times, including periods of startup, shutdown, and malfunction, the permittee shall, to the extent practicable, maintain and opera te any permitted plant equipment, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are be ing used will be based on information available to the Executive Secretary which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source. [Authority gran ted under R307-401-8(2) and 40 CFR 60.11(d) and 40 CFR 63.6 (Subpart A); condition originated in DAQE-AN0303012-06]

II.B.1.a.1 Monitoring:

Records required for this permit cond ition will serve as monitoring.

Issued December 1, 2006 Page 10 Title V Operating Permit #2300015002II.B.1.a.2 Recordkeeping:

Permittee shall document activities performed to assure proper operation and

maintenance. Records shall be maintain ed in accordance with Provision I.S.1 of this permit.

II.B.1.a.3 Reporting:

There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.1.b Condition:

The permittee shall comply with the applicab le requirements for recycling and emission reduction for class I and class II refrigerants pursuant to 40 CFR 82, Subpart F - Recycling and Emissions Reduction. [Authority granted under 40 CFR 82.150(b); condition originated in 40 CFR 82]

II.B.1.b.1 Monitoring:

The permittee shall certify, in the a nnual compliance statement required in Section I of this permit, its compliance status with the requirements of 40 CFR 82, Subpart F.

II.B.1.b.2 Recordkeeping:

All records required in 40 CFR 82, Subpart F shall be maintained consistent with the requirements of Provision S.1 in Section I of this permit.

II.B.1.b.3 Reporting:

All reports required in 40 CFR 82, Subpar t F shall be submitted as required. There are no additional reporting requiremen ts except as outlined in Section I of this permit.

II.B.1.c Condition:

The permittee shall comply with the appli cable requirements for servicing of motor vehicle air conditioners pursuant to 40 CFR 82, Subpart B - Servicing of Motor Vehicle Air Conditioners. [Authority granted under 40 CFR 82.30(b); condition originated in 40 CFR 82]

II.B.1.c.1 Monitoring:

The permittee shall certify, in the a nnual compliance statement required in Section I of this permit, its compliance status with the requirements of 40 CFR 82, Subpart B.

II.B.1.c.2 Recordkeeping:

All records required in 40 CFR 82, Subpart B shall be maintained consistent with the requirements of Provision S.1 in Section I of this permit.

II.B.1.c.3 Reporting:

All reports required in 40 CFR 82, Subpart B shall be submitted as required. There are no additional reporting requiremen ts except as outlined in Section I of this permit.

Issued December 1, 2006 Page 11 Title V Operating Permit #2300015002II.B.1.d Condition:

Visible emissions shall be no greater than 20 percent opacity unless otherwise specified in this permit. [Authority granted under R307-201-3(2); condition originated in R307- 201-3(2) & DAQE-AN0303012-06]

II.B.1.d.1 Monitoring:

(a) The permittee shall conduct a monthly 1-minute visible emissions test of each affected source in accordance with 40 CFR 60, Appendix A, Method 22. The test must be conducted while the affected source is in operation. (b) If no visible emissions are observed in six consecutive monthly tests for any affected source, the permittee may decrease the frequency of testing from monthly to semi-annually for that affected source. If visible emissions are observed during any semi-annual test, th e permittee must resume testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (c) If no visible emissions are observed during the semi-annual test for any affected source, the permittee may decrease the frequency of testing from semiannually to annually for that affected source. If visible emissions are observed during any annual test, the permittee shall resume testing of that affected source on a monthly basis and ma intain that schedule until no visible emissions are observed in six consecutive monthly tests. (d) If visible emissions are observed during any Method 22 test, the permittee

shall conduct a i. six minute test of opacity in accordance with 40 CFR 60, Appendix A, Method 9 for point sources, or ii. one minute test of opacity with five second observation intervals in

accordance with 58 FR 61640 Method 203C for fugitive emission

sources. The Method 9 or 203C test must begin within one hour of any observation of

visible emissions.

II.B.1.d.2 Recordkeeping:

Records of visible emission tests performed and data required by 40 CFR 60, Appendix A, Method 22, Method 9, or 58 FR 61640, Method 203C shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.d.3 Reporting:

There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.1.e Condition:

All unpaved roads, other unpa ved operational areas that are used by mobile equipment, and all disturbed surfaces not involved with operations shall be water sprayed and/or chemically treated to control fugitive dust. Treatment shall be of sufficient frequency and quantity to minimize fugitive dust as necessary to meet any applicable opacity limitations of this permit. The permittee is not required to apply water to surfaces during freezing

conditions. If chemical treatment is to be used, the plan shall be pre-approved by the Executive Secretary. [Authority granted under R307-401-8(1)(a ) [BACT]; condition originated in DAQE-AN0303012-06]

Issued December 1, 2006 Page 12 Title V Operating Permit #2300015002II.B.1.e.1 Monitoring:

Records required for this permit cond ition will serve as monitoring.

II.B.1.e.2 Recordkeeping:

Instances of water and/or chemical appli cation to unpaved areas shall be recorded and maintained by the permittee. The ambient temperature shall be recorded any time water should be applied but can no t be due to freezing conditions.

II.B.1.e.3 Reporting:

There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.1.f Condition:

All paved roads and paved operational areas sh all be swept and/or water sprayed to minimize fugitive dust. The sweeping and/ or water spray shall be conducted as dry

conditions warrant or as determined necessar y by the Executive Secretary. [Authority granted under R307-401-8(1)(a) [BACT]; condition originated in DAQE-AN0303012- 06]

II.B.1.f.1 Monitoring:

Records required for this permit cond ition will serve as monitoring.

II.B.1.f.2 Recordkeeping:

Instances of each sweeping event or water application to the paved areas shall be recorded and maintained by the permittee.

II.B.1.f.3 Reporting:

There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.1.g Condition:

For all emission units subject to 40 CFR 63 Subpart LLL:

The permittee shall prepare and implement an operation and maintenance (O & M) plan in accordance with 40 CFR 63.1350(a). The pl an shall include the following elements:

(A) Procedures for proper operation and maintenance of the affected source and air pollution control devices in order to meet the emission and operating limits of this permit.

(B) Corrective actions to be taken if visibl e emissions are observed from the raw mill and finish mill sweep and air separator pollution control devices during a daily Method

22 test.

(C) Procedures to be used during an inspection of the components of the combustion system of the in-line kiln/raw mill which is to be performed at least once per year.

(D) Procedures to be used to periodically monitor affected sources other than in-line kiln/raw mills, clinker coolers, and finish mills which are subject to opacity

standards.

Issued December 1, 2006 Page 13 Title V Operating Permit #2300015002Failure to comply with any provision of the operations and maintenance plan shall be a violation of the standard. [Authority granted under 40 CFR 63.1350; condition originated in 40 CFR 63 (Subpart LLL)]

II.B.1.g.1 Monitoring:

Records required for this permit cond ition will serve as monitoring.

II.B.1.g.2 Recordkeeping:

The permittee shall maintain files of all information (including all reports and notifications) required by this condition in a form suitable and readily available for expeditious inspection and review. Th ese files shall be retained for at least five years following the date of each occurrence, measurement, maintenance, corrective action, report or record. At a minimum, the most recent two years of

data shall be retained on site. The remain ing three years of data may be retained off site. The files may be maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or on microfiche . Requirements of Provision I.S.1 of this permit also apply. (origin: 40 CFR 63.1355)

II.B.1.g.3 Reporting:

In addition to the requirements in Secti on I of this permit, one summary report shall be submitted semiannually for th e hazardous air pollutants monitored at each affected source. The summary re port shall be entitled "Summary Report - Gaseous and Opacity Excess Emission and Continuous Monitoring System Performance" and shall contain the following information:

(A) The company name and address of the affected source; (B) An identification of each hazardous air pollutant monitored at the affected

source; (C) The beginning and ending dates of the reporting period; (D) A brief description of the process units; (E) The emission and operating parame ter limitations from 40 CFR 63 Subpart
LLL; (F) The monitoring equipment manufacturer(s) and model number(s); (G) All exceedances of maximum control device inlet gas temperature limits; (H) All failures to calibrate thermoc ouples and other temperature sensors as required, (I) All failures to maintain the activated carbon injection rate, and the activated carbon injection carrier gas flow rate or pressure drop, as applicable; (J) The results of any combustion sy stem component inspections conducted within the reporting period; (K) All failures to comply with any provision of the operation and maintenance plan; (L) The date of the latest CMS certification or audit; (M) The total operating time of the affected source during the reporting period; (N) An emission data summary (or similar summary if the owner or operator monitors control system parameters), including the total duration of excess emissions during the reporting period (recorded in minutes for opacity and hours for gases), the total duration of excess emissions expressed as a percent of the total source operating time during that re porting period, and a breakdown of the total duration of excess emissions during the reporting period into those that are

Issued December 1, 2006 Page 14 Title V Operating Permit #2300015002due to startup/shutdown, control equipment problems, process problems, other known causes, and other unknown causes; (O) A CMS performance summary (or similar summary if the owner or operator monitors control system parameters), including the total CMS downtime during the reporting period (recorded in minutes for opacity and hours for gases), the total duration of CMS downtime expressed as a percent of the total source operating time during that reporting period, and a breakdown of the total CMS downtime during the reporting period into periods that are due to monitoring equipment malfunctions, nonmonitoring equipment malfunctions, quality assurance/quality control calibrations, other known causes, and other unknown

causes; (P) A description of any changes in CMS, processes, or controls since the last reporting period; (Q) The name, title, and signature of the r esponsible official who is certifying the accuracy of the report; and (R) The date of the report.

The owner or operator shall submit all reports to the Executive Secretary as well as a copy of each report to the EPA Regional office at:

EPA Region VIII

Director

Air and Toxics Division

999 18th St. 1 Denver Place, Suite 300 Denver, CO 80202-2405

The regional office may waive this requirement for any reports at its discretion. (origin: 40 CFR 63.10(e)(3)(vi) via 40 CFR 63.1354(b)(9))

II.B.1.h Condition:

For all emission units subject to 40 CFR 63 Subpart LLL:

(i) The permittee must implement a written startup, shutdown, and malfunction plan that describes, in detail, procedures for operating and maintaining the affected emission unit during periods of startup, shutdown, and ma lfunction, and a program of corrective action for malfunctioning process and air pollution c ontrol and monitoring equipment used to comply with the relevant standard. [40 CFR 63.6(e)(3)(i)]

(ii) During periods of startup, shutdown, a nd malfunction, the permittee must operate and maintain the affected emission unit (incl uding associated air pollution control and monitoring equipment) in accordance with th e procedures specified in the startup, shutdown, and malfunction plan developed under paragraph (i) of this condition. [40 CFR 63.6(3)(3)(ii)]

(iii) The permittee must maintain a current startup, shutdown, and malfunction plan and must make the plan available upon request for inspection and copying by the Executive Secretary. In addition, if the startup, s hutdown, and malfunction pl an is subsequently revised as provided in paragraph (v) of this condition, the permittee must maintain each previous (i.e., superseded) version of the startup, shutdown, and malfunction plan, and must make each such previous version av ailable for inspection and copying by the

Issued December 1, 2006 Page 15 Title V Operating Permit #2300015002Executive Secretary for a period of 5 years after revision of the plan. If at any time after adoption of a startup, shutdown, and malfunction plan the affected emission unit ceases operation or is otherwise no longer subject to the provisions of 40 CFR 63, the permittee must retain a copy of the most recent plan for 5 years from the date the affected emission unit ceases operation or is no longer subject to 40 CFR 63 and must make the plan available upon request for inspection and co pying by the Executive Secretary. [40 CFR 63.6(e)(3)(v)]

(iv) To satisfy the requirements of this c ondition to develop a startup, shutdown, and malfunction plan, the permittee may use the affected emission unit's standard operating procedures (SOP) manual, or an Occupational Safety and Health Administration (OSHA) or other plan, provided the alternative plans meet all the requirements of this condition and are made available for inspection when requested by the Executive Secretary. [40 CFR 63.6(e)(3)(vi)]

(v) The permittee may periodically revise the startup, shutdown, and malfunction plan as necessary to satisfy the requirements of 40 CF R 63 or to reflect changes in equipment or procedures at the affected emission unit. Ho wever, each such revision to a startup, shutdown, and malfunction plan must be reported in the semiannual report required by this permit. If the startup, shutdown, and ma lfunction plan fails to address or inadequately

addresses an event that meets the characteris tics of a malfunction but was not included in the startup, shutdown, and malfunction plan at the time the permittee developed the plan, the permittee must revise the startup, shutdown, and malfunction plan within 45 days after the event to include detailed procedur es for operating and maintaining the affected emission unit during similar malfunction events and a program of corrective action for similar malfunctions of process or air polluti on control and monitoring equipment. In the event that the permittee makes any revision to the startup, shutdown, and malfunction plan which alters the scope of the activiti es at the affected emission unit which are deemed to be a startup, shutdown, or malfunction, or otherwise modifies the applicability of any emission limit, work practice requirement, or other requirement in a standard established under 40 CFR 63, the revised plan shall not take effect until after the permittee has provided a written notice d escribing the revision to the permitting authority. [40 CFR 63.6(e)(3)(viii)]

(vi) Any revisions made to the startup, shutdown, and malfunction plan in accordance with the procedures established by 40 CFR 63 shall not be deemed to constitute permit revisions under this permit. Moreover, none of the procedures specified by the startup, shutdown, and malfunction plan shall be deemed to fall within the permit shield provision in this permit. [40 CFR 63.6(e)(3)(ix)] [Authority granted under 40 CFR 63 Subpart A, LLL; condition originated in 40 CFR 63 (Subpart LLL)]

II.B.1.h.1 Monitoring:

Records required for this permit cond ition will serve as monitoring.

II.B.1.h.2 Recordkeeping:

The permittee shall maintain relevant records for the affected emission unit of—

(i) The occurrence and duration of each startup, shutdown, or malfunction of operation (i.e., process equipment); [40 CFR 63.10(b)(2)(i)]

Issued December 1, 2006 Page 16 Title V Operating Permit #2300015002(ii) The occurrence and duration of each malfunction of the required air pollution control and monitoring equipment; [40 CFR 63.10(b)(2)(ii)]

(iii) All required maintenance performed on the air pollution control and monitoring equipment; [40 CFR 63.10(b)(2)(iii)]

(iv) Actions taken during periods of startup, shutdown, and malfunction (including corrective actions to rest ore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation)

when such actions are different from th e procedures specified in the startup, shutdown, and malfunction plan; [40 CFR 63.10(b)(2)(iv)]

(v) All information necessary to demons trate conformance with the startup, shutdown, and malfunction plan when all ac tions taken during periods of startup, shutdown, and malfunction (including corrective actions to restore malfunctioning process and air pollution cont rol and monitoring equipment to its normal or usual manner of operation) are consistent with the procedures specified in such plan. These records may take the fo rm of a "checklist," or other effective form of recordkeeping that confirms conformance with the startup, shutdown, and malfunction plan for that event. [40 CFR 63.6(e)(3)(iii) & 40 CFR 63.10(b)(2)(v)]

(vi) If an action taken by the permittee during a startup, shutdown, or malfunction (including an action taken to correct a malfunction) is not consistent with the procedures specified in the startup, shutdown, and malfunction plan, and the affected emission unit exceeds any applicable emission limitation in the relevant emission standard, then the permittee must record the actions taken for that event. [40 CFR 63.6(e)(3)(iv)]

The permittee shall maintain files of all information (including all reports and notifications) required by this condition r ecorded in a form suitable and readily available for expeditious inspection and revi ew. The files shall be retained for at least five years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. At a minimum, the most recent two years of data shall be retained on s ite. The remaining three years of data may be retained off site. The files may be maintained on microfilm, on a computer, on computer floppy disks, on magnetic tape disks, or on microfiche. [40 CFR 63.1355(a) & 40 CFR 63.10(b)(1)]

Requirements of Provision I.S.1 of this permit also apply.

II.B.1.h.3 Reporting:

In addition to the reporting requirements speci fied in Section I of this permit, in the event of a startup, shutdown or malfunction, the following reporting requirements shall be followed:

(i) Periodic startup, shutdown, and malf unction reports. If actions taken by the permittee during a startup, shutdown, or malfunction (including actions taken to correct a malfunction) are consistent with the procedures specified in the startup, shutdown, and malfunction plan, the permitt ee shall state such information in a startup, shutdown, and malfunction report. Otherwise, such a report shall identify

Issued December 1, 2006 Page 17 Title V Operating Permit #2300015002any instance where any action taken by a permittee during a startup, shutdown, or malfunction (including actions taken to co rrect a malfunction) is not consistent with the startup, shutdown, and malfunction plan, but the affected emission unit does not exceed any applicable emission limitation in the relevant emission standard. Such a report shall also incl ude the number, duration, and a brief description for each type of malfuncti on which occurred during the reporting period and which caused or may have cau sed any applicable emission limitation to be exceeded. Reports shall only be required if a startup, shutdown, or malfunction occurred during the reporting period. The startup, shutdown, and malfunction report shall consist of a letter, containing the name, title, and signature of the responsible official who is certifying its accuracy, that shall be submitted to the Executive Secretary semi annually. The startup, shutdown, and malfunction report shall be delivered or postmarked by the 30th day following

the end of each calendar half. The start up, shutdown, and malfunction report may be submitted simultaneously with th e excess emissions and continuous monitoring system performance reports. [40 CFR 63.1354(b)(4) & 40 CFR 63.10(d)(5)(i) & 40 CFR 63.6(e)(3)(iii)]

(ii) Immediate startup, shutdown, and malfunction reports. If an action taken by the permittee during a startup, shutdown, or malfunction (including actions taken to correct a malfunction) is not consiste nt with the procedures specified in the startup, shutdown, and malfunction plan , the permittee shall report the actions taken for that event within 2 working days after commencing actions inconsistent with the plan followed by a letter within 7 working days after the end of the event. The immediate report required unde r this paragraph shall consist of a telephone call or facsimile (FAX) transmission to the Executive Secretary within 2 working days after commencing actions in consistent with the plan, and it shall be followed by a letter, delivered or pos tmarked within 7 working days after the end of the event, that contains the na me, title, and signature of the responsible official who is certifying its accuracy, expl aining the circumstances of the event, the reasons for not following the startup, shutdown, and malfunction plan, and describing all excess emissions and/or parameter monitoring exceedances which are believed to have occurred. [40 CFR 63.6(e)(3)(iv) & 40 CFR 63.10(d)(5)(ii) & 40 CFR 63.1354(b)(5)]

II.B.1.i Condition:

Visible emissions shall be no greater than 10 percent opacity from the baghouses unless otherwise specified in this permit. [Aut hority granted under R307-401-8(1)(a) [BACT]; condition originated in DAQE-AN0303012-06]

II.B.1.i.1 Monitoring:

(a) The permittee shall conduct a monthly 1-minute visible emissions test of each affected source in accordance with 40 CFR 60, Appendix A, Method 22. The test must be conducted while the affected source is in operation. (b) If no visible emissions are observed in six consecutive monthly tests for any affected source, the permittee may decrease the frequency of testing from monthly to semi-annually for that affected source. If visible emissions are observed during any semi-annual test, th e permittee must resume testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests.

Issued December 1, 2006 Page 18 Title V Operating Permit #2300015002(c) If no visible emissions are observed during the semi-annual test for any affected source, the permittee may decrease the frequency of testing from semi-annually to annually for that affected source. If visible emissions are observed during any annual test, the permittee shall resume testing of that affected source on a monthly basis and ma intain that schedule until no visible emissions are observed in six consecutive monthly tests. (d) If visible emissions are observed during any Method 22 test, the permittee shall conduct a 6-minute test of opacity in accordance with 40 CFR 60, Appendix A, Method 9. The Method 9 test must begin within one hour of any observation of visible emissions.

II.B.1.i.2 Recordkeeping:

Records of visual observations perform ed and data required by 40 CFR 60, Appendix A, Method 9 for each determination shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.i.3 Reporting:

There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.1.j Condition:

In accordance with Provision I.L.1 of this permit, the permittee shall submit to the Executive Secretary an annual compliance certif ication, certifying compliance with the terms and conditions contained in this permit, including emission limitations, standards, or work practices no later than December 15, 2006. [Authority gr anted under R307-415- 6c; condition originated in R307-415-6c]

II.B.1.j.1 Monitoring:

Records required for this permit cond ition will serve as monitoring.

II.B.1.j.2 Recordkeeping:

A copy of the compliance certification required by this condition shall be retained for a period of at least five year s and in accordance with Section I of this permit.

II.B.1.j.3 Reporting:

There are no reporting requirements for th is provision except those specified in Section I.L and Section I.S of this permit.

II.B.2 Conditions on Stationary Crusher (211.BF1)

II.B.2.a Condition:

Permittee shall operate water sprays or du st suppression sprays to control fugitive emissions. The sprays shall operate whenev er dry conditions warrant or as determined necessary by the Executive Secret ary. Sprays shall not be required during periods of freezing temperatures. [Authority granted under R307-401-8(1)(a) [BACT]; condition originated in DAQE-AN0303012-06]

II.B.2.a.1 Monitoring:

Visual inspections of the water spray syst em(s) shall be made weekly to ensure proper operating condition.

Issued December 1, 2006 Page 19 Title V Operating Permit #2300015002II.B.2.a.2 Recordkeeping:

An operator’s log shall be maintained of all monitoring provisions listed above. Records of water spray system inspectio ns shall be kept for all periods of operation and the ambient temperature sh all be recorded any time water should be applied but can not be due to freezing conditions.

II.B.2.a.3 Reporting:

There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.2.b Condition:

Visible emissions shall be no greater than 10 percent opacity from the baghouse. [Authority granted under R307-401-8(1)(a) [BACT]; condition originated in DAQEAN0303012-06]

II.B.2.b.1 Monitoring:

Compliance with the visible emission limitation shall be demonstrated by one of the following options.

Option A: (I) Measurement Approach: The permittee shall monitor opacity by conducting daily visual emissions observations in accordance with the procedures of 40 CFR 60, Appendix A, Method 22. (II) Indicator Range: An excursion is defined as the presence of visible emissions. If visible emissions are observed during any Method 22 visible emissions test, the permittee shall: a) Initiate corrective actions, within one-hour; and b) Within 24 hours of the end of the Method 22 test in which visible emissions were observed, conduct a followup Method 22 test of each stack from which visible emissions were observed during the previous Method 22 test. If visible emissions are observed during the followup Method 22 test from any stack from which visible emissions were observed during the previous Method 22 test, conduct a visual opacity test of each stack from which emissions were observed during the follow up Method 22 test in accordance with 40 CFR 60, Appendix A, Method

9. The duration of the Method 9 test shall be 30 minutes. (III) Performance Criteria: a) Data Representativeness: The Met hod 22 test shall be conducted while the affected unit is operating at representative performance conditions. b) QA/QC Practices and Criteria: The visual observer shall be familiar with 40 CFR, Appendix A, Method 22 and follow Method 22 procedures. The opacity determination shall be conducted by a certified VEO in accordance with 40 CFR 60, Appendix A, Method 9. c) Monitoring Frequency: A Method 22 observation shall be performed daily for each affected unit. The duratio n of the Method 22 test shall be 6

minutes. d) Data Collection Procedure: The observation shall be documented by the observer and all data required by 40 CFR 60, Appendix A, Method 9 shall be maintained if the opac ity determination is conducted. e) Averaging Period: None

Issued December 1, 2006 Page 20 Title V Operating Permit #2300015002Option B: (I) Measurement Approach: A BLDS shal l be installed on the baghouse exhaust stack and generate a signal proportional to PM concentration. An alarm shall sound when the signal exceeds a preset limit. (II) Indicator Range: An excursion is defi ned as a signal greater than or equal to 50% of scale during normal operating co nditions. Excursions trigger an inspection, corrective action, and a reporting requirement. The permittee shall maintain and operate the fabric filter such that the bag

leak detector alarm is not activated and alarm condition does not exist for more than 5 percent of the total operating time in a 6-month block period.

Each time the alarm activ ates, alarm time shall be counted as the actual amount of time taken by the permitt ee to initiate corrective actions. If inspection of the fabric filter demonstrates that no corrective actions are necessary, no alarm time shall be counted. (III) Performance Criteria: a. Data Representativeness: 1) For a positive-pressure fabric filter, the bag leak detector shall be installed in the exit vent. For a negative-pressure or induced-air fabric filter, the bag leak detector shall be installed downstream of the fabric filter. If multiple bag leak detectors are required (for either type of fabric filter), detectors may share the system instrumentation

and alarm. 2) The baseline output of the system shall be established as follows: a) Adjust the range and the averaging period of the device; and b) Establish the alarm set points and the alarm delay time. 3) The sensor on the BLDS shall provide output of relative PM

emissions. 4) The BLDS shall have an alarm th at will activate automatically when it detects PM emissions greater than or equal to 50% of scale during normal operating conditions. 5) The presence of an alarm condition shall be clearly apparent to facility operating personnel. b. QA/QC Practices and Criteria: 1) The probe shall be inspected at least monthly for dust buildup. 2) Lens cleaning, O-ring replacement, and window value rechecks shall be performed at least annually. 3) The BLDS shall be certified by the manufacturer to be capable of detecting PM emissions at concentr ations of 10 milligrams per actual cubic meter (0.0044 grains per actual cubic foot) or less. "Certify"

shall mean that the instrument manuf acturer has tested the instrument on gas streams having a range of particle size distributions and confirmed by means of valid filterable PM tests that the minimum detectable concentration limit is at or below 10 milligrams per actual cubic meter (0.0044 grains per actual cubic foot) or less. 4) All BLDS shall be installed, operated, adjusted, and maintained so that they are based on the manufacturer's written specifications and

recommendations. 5) After initial adjustment, the range, averaging period, alarm set points, or alarm delay time shall not be adjusted except as specified in the BLDS standard operating pr ocedure (SOP). In no event shall

Issued December 1, 2006 Page 21 Title V Operating Permit #2300015002the range be increased by more than 100 percent or decreased by more than 50 percent over a 1 calendar year period unless a responsible official as defined in R307-415-3 certifies in writing to the executive secretary that the fabr ic filter has been inspected and found to be in good operating condition. c. Monitoring Frequency: The BLDS signal shall be monitored continuously.

d. Data Collection Procedure: The instantaneous values from the transmitter output shall be displayed an d recorded. All alarms shall be logged electronically. e. Averaging Period: None.

II.B.2.b.2 Recordkeeping:

The following records shall be maintained in accordance with Provision I.S.1 of this permit:

(a) The permittee shall continuously record the output from the BLDS during periods of normal operation. Normal operation does not include periods when the BLDS is being maintained or during startup, shutdown or

malfunction. (b) Alarm times as defined in Monitoring shall be recorded. (c) Records of visual emission observations and visual opacity tests required by 40 CFR 60, Appendix A, Methods 22 and 9 shall be maintained if a BLDS is

not used.

In addition to the recordkeeping requirement s described in Provision I.S.1 of this permit, the permittee shall maintain a file of the occurrence and duration of any excursion, corrective actions taken, and any other supporting information required to be maintained under 40 CFR 64 (such as data used to document the adequacy of monitoring, or records of monitoring maintenance or corrective actions). Instead of paper records, the permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. (40 CFR 64.9(b))

II.B.2.b.3 Reporting:

In addition to the reporting requirement described in Provision I.S.2 of this permit, the monitoring report shall include, at a minimum, the following information, as applicable: (i) Summary information on the number, duration and cause (including unknown cause, if applicable) of excu rsions or exceedances, as applicable, and the corrective actions taken; (40 CFR 64.9(a)(2)(i)) (ii) Summary information on the num ber, duration and cause (including unknown cause, if applicable) for monitor downtime incidents (other than downtime associated with zero and span or other daily calibration checks, if applicable). (40 CFR 64.9(a)(2)(ii))

Issued December 1, 2006 Page 22 Title V Operating Permit #2300015002II.B.3 Conditions on Raw Material Transfer (211.BF2)

II.B.3.a Condition:

Visible emissions shall be no greater than 10 percent opacity. [Authority granted under R307-401-8(1)(a) [BACT]; condition or iginated in DAQE-AN0303012-06]

II.B.3.a.1 Monitoring:

(a) The permittee shall conduct a monthly 1-minute visible emissions test of each affected source in accordance with 40 CFR 60, Appendix A, Method 22. The test must be conducted while the affected source is in operation. (b) If no visible emissions are observed in six consecutive monthly tests for any affected source, the permittee may decrease the frequency of testing from monthly to semi-annually for that affected source. If visible emissions are observed during any semi-annual test, th e permittee must resume testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (c) If no visible emissions are observed during the semi-annual test for any affected source, the permittee may decrease the frequency of testing from semiannually to annually for that affected source. If visible emissions are observed during any annual test, the permittee shall resume testing of that affected source on a monthly basis and ma intain that schedule until no visible emissions are observed in six consecutive monthly tests. (d) If visible emissions are observed during any Method 22 test, the permittee shall conduct a six minute test of opacity in accordance with 40 CFR 60, Appendix A, Method 9. The Method 9 test must begin within one hour of any observation of visible emissions.

II.B.3.a.2 Recordkeeping:

Records of visible emission tests performed and data required by 40 CFR 60, Appendix A, Method 22 and 9 shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.3.a.3 Reporting:

There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.3.b Condition:

Permittee shall operate water sprays or du st suppression sprays to control fugitive emissions. The sprays shall operate whenev er dry conditions warrant or as determined necessary by the Executive Secret ary. Sprays shall not be required during periods of freezing temperatures. [Authority granted under R307-401-8(1)(a) [BACT]; condition originated in DAQE-AN0303012-06]

II.B.3.b.1 Monitoring:

Visual inspections of the water spray syst em(s) shall be made weekly to ensure proper operating condition.

II.B.3.b.2 Recordkeeping:

An operator’s log shall be maintained of all monitoring provisions listed above. Records of water spray system inspectio ns shall be kept for all periods of

Issued December 1, 2006 Page 23 Title V Operating Permit #2300015002operation and the ambient temperature sh all be recorded any time water should be applied but can not be due to freezing conditions.

II.B.3.b.3 Reporting:

There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.4 Conditions on Coal Grinding System (41B.BF2)

II.B.4.a Condition:

Visible emissions shall be less than 20 per cent opacity. [Authority granted under 40 CFR 60.252(a),(c) (Subpart Y); condition originated in 40 CFR 60 (Subpart Y)]

II.B.4.a.1 Monitoring:

A visual observation of each affected emission unit shall be performed on a weekly basis by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The individual is not required to be a certified visible emissions observer (VEO). If any visible emissions are observed, an opacity determination of that emission unit shall be performed by a certified VEO in accordance with 40 CFR 60, Appendix A, Method 9 within 24 hours of the initial observation. For each affected emission unit, if no visible emissions are observed for eight consecutive weeks the observation frequency shall be reduced to a monthly basis. If visible emissions are observed during any monthly observation the frequency shall revert back to a weekly basis.

II.B.4.a.2 Recordkeeping:

Records of visual observations perform ed and data required by 40 CFR 60, Appendix A, Method 9 for each determination shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.4.a.3 Reporting:

There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.4.b Condition:

During all periods of operation, the permittee shall record the operating temperature of the Coal Grinding System baghouse. [Authority granted under 40 CFR 63.8(f); condition originated in Alternative Monitoring EPA Approval 11/6/02]

II.B.4.b.1 Monitoring:

The permittee shall install and operate a temperature alarm on the baghouse inlet in accordance with the manufacturer’s specifications. (origin: Alternative Monitoring EPA Approval 11/6/02)

II.B.4.b.2 Recordkeeping:

Records required by this permit condition and copies of the manufacturer’s alarm specifications shall be maintained in accordance with Provision I.S.1 of this permit and made available for review by the Executive Secretary or his representative. (origin: Alternative Monitoring EPA Approval 11/6/02)

Issued December 1, 2006 Page 24 Title V Operating Permit #2300015002II.B.4.b.3 Reporting:

There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.4.c Condition:

The permittee shall not cause to be discharged into the atmosphere from any thermal dryer gases which contain particulate matter in excess of 0.070 g/dscm (0.031 gr/dscf). [Authority granted under 40 CFR 60.252(a) (Subpart Y); condition originated in 40 CFR 60 (Subpart Y)]

II.B.4.c.1 Monitoring:

Stack testing shall be performed as specified below:

(a) Testing and Frequency. Emissions shall be tested every five years, based on the date of the most recent stack test. Tests may also be required at the direction of the Executive Secretary.

(b) Notification. At least 30 days be fore the test, the source shall notify the Executive Secretary of the date, time, and place of testing and provide a copy of the test protocol. The source shall attend a pretest conference if determined necessary by the Executive Secretary.

(c) Methods.

(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60, Appendix A, Method 1, and Occupational Safety and Health Administration (OSHA) and/or Mine Safety and Health Administration (MSHA)-approved access shall be provided to the test location.

(2) Sample Method - 40 CFR 60. Appendix A, Method 5 shall be used to determine the particulate matter concen tration and the volumetric flow rate of the effluent gas. The sampling time and sample volume shall be at least 60 minutes and 0.85 dscm (30 dscf). Sampling shall begin no less than 30 minutes after startup and shall terminate be fore shutdown procedures begin.

(d) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the appropriate methods above shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Executive Secretary to gi ve the results in the specified units of

the emission limitation.

(e) Production Rate During Testing. The production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three (3) years.

In addition to the stack testing requirement s, the permittee shall install, calibrate, maintain, and continuously operate a mon itoring device for the measurement of the temperature of the gas stream at the exit of the thermal dryer on a continuous basis. The monitoring device shall be certified by the manufacturer to be accurate within +/- 1.7 degrees Celsius (+/- 3 degrees Fahrenheit). The

Issued December 1, 2006 Page 25 Title V Operating Permit #2300015002monitoring device shall be recalibrate d annually in accordance with the manufacturer's written requirements or recommendations.

II.B.4.c.2 Recordkeeping:

Results of monitoring shall be maintain ed in accordance with Provision I.S.1 of this permit. In addition, results of all stack testing shall be recorded and

maintained in accordance with th e associated test method.

II.B.4.c.3 Reporting:

The results of stack testing shall be s ubmitted to the Executive Secretary within 60 days of completion of the testing. Reports shall clearly identify results as compared to permit limits and indicate compliance status. There are no additional reporting requirements for th is provision except those specified in Section I of this permit.

II.B.5 Conditions on Coal Silo (41B.BF1)

II.B.5.a Condition:

Visible emissions shall be less than 20 per cent opacity. [Authority granted under 40 CFR60.252(c) (Subpart Y); condition originated in 40 CFR 60 (Subpart Y) & DAQEAN0303012-06]

II.B.5.a.1 Monitoring:

A visual observation of each affected emission unit shall be performed on a weekly basis by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The individual is not required to be a certified visible emissions observer (VEO). If any visible emissions are observed, an opacity determination of that emission unit shall be performed by a certified VEO in accordance with 40 CFR 60, Appendix A, Method 9 within 24 hours of the initial observation. For each affected emission unit, if no visible emissions are observed for eight consecutive weeks the observation frequency shall be reduced to a monthly basis. If visible emissions are observed during any monthly observation the frequency shall revert back to a weekly basis.

II.B.5.a.2 Recordkeeping:

Records of visual observations perform ed and data required by 40 CFR 60, Appendix A, Method 9 for each determination shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.5.a.3 Reporting:

There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.6 Conditions on Kiln & Pre-Calciner and Raw Mill (317.BF1)

II.B.6.a Condition:

Emissions of particulate matter shall be no gr eater than 0.30 lbs per ton (0.15 kg/Mg) of kiln feed (dry basis). [Authority granted under R307-401-8(1)(a) [BACT] & 40 CFR 63 (Subpart LLL); condition originated in DAQE-AN0303012-06 & 40 CFR 63 (Subpart LLL)]

Issued December 1, 2006 Page 26 Title V Operating Permit #2300015002II.B.6.a.1 Monitoring:

Stack testing shall be performed as specified below:

(a) Frequency. Emissions shall be tested every five (5) years, based on the date of the most recent stack test. Tests may also be required at the direction of the Executive Secretary.

(b) Notification. At least 60 days be fore the test, the source shall notify the Executive Secretary of the date, time, and place of testing and provide a copy of the test protocol. The source shall attend a pretest conference if determined necessary by the Executive Secretary.

(c) Methods.

(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60, Appendix A, Method 1, and Occupational Safety and Health Administration (OSHA) or Mi ne Safety and Health Administration (MSHA) approvable access shall be provided to the test location.

(2) Sample Method - 40 CFR 60, Appendix A, Method 5 shall be used to determine particulate matter emissions and the volumetric flow rate of the effluent gas. Each test shall consist of three separate runs. Each run shall be conducted for at least one hour, and the minimum sample volume shall be 0.85 dscm (30 dscf). The average of the th ree runs shall be used to determine compliance. The emission rate of particulate matter shall be computed for each run using the equation in 40 CFR 63.1349(b)(1).

(d) Production Rate During Testing. The production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three (3) years.

II.B.6.a.2 Recordkeeping:

Results of all stack testing shall be r ecorded and maintained in accordance with

the associated test method and Provision S. 1 in Section I of this permit.

II.B.6.a.3 Reporting:

The results of stack testing shall be s ubmitted to the Executive Secretary within 60 days of completion of the testing. Reports shall clearly identify results as compared to permit limits and indicate compliance status. There are no additional reporting requirements for th is provision except those specified in Section I of this permit.

II.B.6.b Condition:

Emissions of PM 10 shall be no greater than 20.5 lbs/hr. [Authority granted under R307- 401-8(1)(a) [BACT]; condition originated in DAQE-AN0303012-06]

II.B.6.b.1 Monitoring:

(a) Stack testing shall be performed as specified below: (i) Frequency. Emissions shall be test ed every three years. Tests may also be required at the direction of the Executive Secretary.

Issued December 1, 2006 Page 27 Title V Operating Permit #2300015002(ii) Notification. At least 30 days before the test, the source shall notify the Executive Secretary of the date, time, and place of testing and provide a copy of the test protocol. The source shall attend a pretest conference if determined necessary by th e Executive Secretary. (iii) Methods. a. Sample Location - the emission point shall conform to the requirements of 40 CFR 60, Appendi x A, Method 1, and Occupational Safety and Health Administration (OSHA) and/or Mine Safety and Health Administration (MSHA) appr oved access shall be provided to the

test location. b. For stacks in which no liquid drops are present, the following methods shall be used: 40 CFR 51, Appendix M, Methods 201 or 201a. Method 202 may be used to measure condensible particulate matter. c. For stacks in which liquid drops are present, methods to eliminate the liquid drops should be explored. If no reasonable method to eliminate the drops exists, then the following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, or 5e as appropriate. The back half condensibles shall also be tested using a method specified by the Executive Secretary. All particulate captured shall be considered PM 10

. d. The back half condensibles shall not be used for compliance demonstration but shall be used for inventory purposes. (iv) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the appropriate methods above shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Executive Secretary to give the results in the specified

units of the emission limitation. (v) Production Rate During Testing. The production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three (3) years. (b) Optical density shall be used as an indicator to provide reasonable assurance of compliance with the PM 10 emission limitation as specified below. (i) Measurement Approach: Opacity sh all be determined using a continuous opacity monitor (COM) located in th e exhaust stack. The opacity shall be mathematically converted to units of optical density. (ii) Indicator Range: An excursion is defined as a 24-hour block average optical density in excess of 0.041 excl uding periods of st artup, shutdown, or malfunction. Excursions trigger an inspection, corrective action, and a reporting requirement. Once every three years, during the stack test required in (a) above, the permittee shall acquire new test data to evaluate or update the excursion optical density value. The procedure for collecting new test data is described in a reviewer comment at the end of this permit. (iii) Performance Criteria: a. Data Representativeness: The COM shall be installed in a representative location in the exhaus t stack and shall be calibrated, maintained, and operated in accordance with 40 CFR Part 60 Appendix B Performance Specification 1 and R307-170. b. QA/QC Practices and Criteria: The COM shall be calibrated, maintained, and operated in accordance with 40 CFR Part 60 Appendix B Performance Specification 1, R307-170, and the

manufacturer’s written recommendations.

Issued December 1, 2006 Page 28 Title V Operating Permit #2300015002c. Monitoring Frequency: Opacity shall be monitored continuously and a data point recorded electronically every 10 seconds. d. Data Collection Procedure: The 10-second opacity data shall be used to calculate 6-minute opacity averages. The 6-minute opacity averages shall be mathematically converted to units of optical density. The 6-minute optical density values shall be averaged over a 1-hour block. The 1-hour optical density averages shall be used to calculate a 24-hour block average. The 24-hour block average optical density shall be recorded and stored electronically. e. Averaging Period: 24-hour block average.

II.B.6.b.2 Recordkeeping:

Results of all stack testing shall be r ecorded and maintained in accordance with the associated test method and Provision I.S.1 of this permit.

Records of the 24-hour block average optical density values shall be maintained in accordance with Provision I.S.1 of this permit. In addition, the permittee shall

maintain records of: a) all test data from the most recent stack test and the calculations that were used to evaluate or revise the excursion optical density value. b) all continuous opacity monitor (COM) parameters, performance test measurements, all COM performance evaluations, all COM calibration checks, all COM adjustments and maintenance, and all other information required by R307-170 in a permanent form suitable for inspection. c) the occurrence and duration of any ex cursion, corrective actions taken, and any other supporting information required to be maintained under 40 CFR 64 (such as data used to document the ade quacy of monitoring, or records of monitoring maintenance or corrective acti ons). Instead of paper records, the permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of

such alternative media allows for e xpeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. (40 CFR 64.9(b))

II.B.6.b.3 Reporting:

In addition to the reporting requirements in Provision I.S.2 of this permit, (a) Monitoring reports shall include, at a minimum, the following information, as applicable: (i) Summary information on the number, duration and cause (including unknown cause, if applicable) of excursions or exceedances, as applicable, and the corrective actions taken; (40 CFR 64.9(a)(2)(i)) (ii) Summary information on the num ber, duration and cause (including unknown cause, if applicable) for monitor downtime incidents (other than downtime associated with zero and span or other daily calibration checks, if applicable). (40 CFR 64.9(a)(2)(ii)) (b) The results of stack testing shall be submitted to the Executive Secretary within 60 days of completion of the t esting. Reports shall clearly identify results as compared to permit limits and indicate compliance status.

Issued December 1, 2006 Page 29 Title V Operating Permit #2300015002II.B.6.c Condition:

Visible emissions shall be no greater than 20 percent opacity. [Authority granted under 40 CFR 63, Subpart LLL; condition originated in DAQE-AN0303012-06]

II.B.6.c.1 Monitoring:

The permittee shall calibrate, maintain and operate a continuous monitoring system for measuring the opacity of emi ssions discharged to the atmosphere in accordance with R307-170 and 40 CFR 63.8 (Subpart A), and shall record the output of the system. The output shall be reviewed at least monthly for compliance with the opacity limit; complia nce is to be based on the percent opacity averaged over six consecutive minutes.

II.B.6.c.2 Recordkeeping:

Results of opacity observations shall be recorded and maintained as required in R307-170 and as described in Provision I.S.1 of this permit.

II.B.6.c.3 Reporting:

The permittee shall comply with the reporting provisions in R307-170-9 and any additional reporting provisions contai ned in Section I of this permit.

The quarterly reports required in R307-170-9 are considered prompt notification of permit deviations required in Provision I.S.2.c of this permit if all information required by Provision I.S.2.c is included in the report.

II.B.6.d Condition:

Emissions of NO

x shall be no greater than 2,165 tons per rolling 12-month period. [Authority granted under R307-401-8(1)(a) [BACT]; condition originated in DAQEAN0303012-06]

II.B.6.d.1 Monitoring:

While the affected emission unit is operating, hourly NO

x emission rates expressed in tons per hour shall be de termined in accordance with R307-170 using the appropriate conversion factors. The applicable performance specification in R307-170 shall be 40 CFR 60, Appendix B, Performance Specification 6 - "Specifications and Test Procedures for Continuous Emission Rate Monitoring Systems in Stationary Sources". By the 25th day of each month

a new 12-month NO

x emission total for the common stack shall be calculated as the sum of the monthly NO

x emission totals for each of the previous 12 months.

II.B.6.d.2 Recordkeeping:

The permittee shall keep the records spec ified in R307-170-8 and any additional records required by provision I.S.1 of this permit. These records shall be

maintained in accordance with Provision I.S.1.

II.B.6.d.3 Reporting:

The permittee shall comply with the reporting provisions in R307-170-9 and any additional reporting provisions contai ned in Section I of this permit.

The quarterly reports required in R307-170-9 are considered prompt notification of permit deviations required in Provision I.S.2.c of this permit if all information required by Provision I.S.2.c is included in the report.

Issued December 1, 2006 Page 30 Title V Operating Permit #2300015002II.B.6.e Condition:

The permittee shall use only the following fuels in the kiln and pre-calciner:

A. Coal B. Diaper Derived Fuel (DDF) C. Tire Derived Fuel (TDF)

D. Natural Gas

E. Coke

F. Fuel Oil

G. Used Oil Fuel H. Synthetic Fuel

I. Wood J. Coal Additives consisting of alternative fuels approved by the Executive Secretary. Prior to burning any proposed coal additive, the permittee shall obtain approval from the Executive Secretary. To obtain approval, the permittee shall submit Material Safety Data Sheets (MSDS) or the resu lts of suitable tests giving data similar to a Proximate and Ultimate analysis of the proposed coal additive.

Approval by the Executive Secretary shall consist of a letter approving the use of the proposed coal additive. Approval is not required to change from one previously approved coal additive to anot her previously approved coal additive.

The average quantity of coal add itives burned shall not be greater than 15% of the total daily heat input of the k iln and precalciner. The permittee may increase the average quantity of coal additives up to 25% of the total daily heat input of the kiln and precalciner upon approval by the Executive Secretary in accordance with the approval process described for new coal additives above.

Additionally, the permittee shall be limited to a maximum TDF consumption not to exceed 15% of the combined energy input to the rotary kiln and pre-calciner on a monthly basis. [Authority granted under R 307-401-8(1)(a) [BACT]; condition originated in DAQE-AN0303012-06]

II.B.6.e.1 Monitoring:

Records required for this permit cond ition will serve as monitoring.

II.B.6.e.2 Recordkeeping:

Within the first 25 days of each month, a rolling 12-month total of fuel usage shall be determined using records from th e previous 12 months. The fuel usage records shall include the type, quantity, and respective heating value for each material used as fuel. Copies of Execu tive Secretary approval of each coal

additive shall be maintained. Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.6.e.3 Reporting:

There are no reporting requirements for th is provision except those specified in Section I of this permit.

Issued December 1, 2006 Page 31 Title V Operating Permit #2300015002II.B.6.f Condition:

Consumption of used oil fuel shall be no gr eater than 85,724 gallons per rolling 12-month period. [Authority granted under R307-401- 8(1)(a) [BACT]; condition originated in DAQE-AN0303012-06]

II.B.6.f.1 Monitoring:

Consumption shall be determined with in the first 25 calendar days of each month, for the previous month, us ing purchase records and inventory

information. The total shall then be adde d to the previous 11 months total for a 12 month rolling total.

II.B.6.f.2 Recordkeeping:

Records of used oil combusted shall be kept daily in a supervisor log for all periods when the plant is in operation. Records shall be kept in accordance with Provision I.S.1 of this permit.

II.B.6.f.3 Reporting:

There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.6.g Condition:

Permittee shall meet the following requirements when used oil or tire derived fuel (TDF) is burned in the rotary kiln:

Combustion gas temperature at the rotary kiln exit shall not drop below 1500 degrees Fahrenheit for more than five minutes in any 60-minute period.

Oxygen content at the kiln system ID fan shall not drop below 2% for more than five minutes in any 60-minute period. [Authorit y granted under R307-401-8(1)(a) [BACT]; condition originated in DAQE-AN0303012-06]

II.B.6.g.1 Monitoring:

The permittee shall continuously monitor the temperature and oxygen content at all times used oil or TDF is burned in the kiln using equipment approved by the Executive Secretary. Calibration procedur e and frequency shall be according to manufacturers specifications. Use of factory calibrated thermocouples for temperature measurement is approved. All monitoring equipment for both temperature and oxygen shall be located such that an inspector can safely read the output at any time.

Additionally, the permittee shall monitor th e quantities and times that used oil or

TDF is burned in kiln.

II.B.6.g.2 Recordkeeping:

Permittee shall record the temperature and oxygen content at no less than every 5 minutes during operations when used oil or TDF is burned in the kiln. The permittee shall record the quantities and tim es when used oil or TDF is burned in

the kiln.

Issued December 1, 2006 Page 32 Title V Operating Permit #2300015002II.B.6.g.3 Reporting:

There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.6.h Condition:

The concentration of contaminants or paramete rs in any used oil fuel burned in the Kiln shall not exceed the following levels: Arsenic 5 ppm by weight, Barium 100 ppm by weight, Cadmium 2 ppm by weight, Chromium 10 ppm by weight, Lead 100 ppm by weight, Total Halogens 1,000 ppm by weight , Sulfur 0.5 percent by weight, and Flash Point not less than 100 degrees F. Used o il exceeding any of the above contaminants shall not be burned until the permittee has submitted and received approval of a modeling analysis of the projected emissions for each contaminant from the Executive Secretary. The modeling analysis shall show in each case that the resulting concentration of

contaminant in the ambient air does not ex ceed the TLV/100 value at the fence line for the given contaminant. Any used oil fuel that contains more than 1,000 ppm by weight of total halogens shall be considered a hazardous waste and shall not be burned in the kiln. [Authority granted under R307-401-8(1)(a) [BACT]; condition originated in DAQEAN0303012-06]

II.B.6.h.1 Monitoring:

The permittee shall maintain test certificati on data for each load of used oil fuel received. Certification shall be either by permittee testing or test reports provided by the used oil fuel vendor. The used oil fuel shall be tested for halogen content by ASTM Method D- 808-81, EPA Method 8240 or Method 8260 before used oil fuel is transferred to a holding tank or burned.

II.B.6.h.2 Recordkeeping:

Records of used oil fuel consumption and the test reports shall be kept for all periods when the plant is in operation.

II.B.6.h.3 Reporting:

There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.6.i Condition:

As part of demonstration of compliance with the dioxin/furan emission limitation in this permit, the permittee shall operate the kiln such that the temperature of the gas at the inlet to the kiln particulate matter control device (PMCD) and alkali bypass PMCD, if applicable, does not exceed the applicable temperature limits (for both raw mill operating and not operating) as determined and established in accordance with 40 CFR 63.1349(b)(3)(iv). The permittee shall conduct an inspection of the components of the combustion system of each kiln or in-line kiln/raw mill at least once per year. [Authority granted under 40 CFR 63, Subpart LLL; conditio n originated in 40 CFR 63 (Subpart LLL)]

II.B.6.i.1 Monitoring:

(a) The permittee shall install, calibrate , maintain, and continuously operate a

continuous monitor to record the te mperature of the exhaust gases from the kiln, in-line kiln/raw mill and alkali bypass, if applicable, at the inlet to, or upstream of, PM control devices. The recorder response range shall include zero and 1.5 times either of the average temperatures established during the

Issued December 1, 2006 Page 33 Title V Operating Permit #2300015002performance test. The reference met hod shall be a National Institute of Standards and Technology calibrated reference thermocouple-potentiometer system or alternate reference, subject to approval. (b) The permittee shall monitor and contin uously record the temperature of the exhaust gases from the kiln, in-line kiln/raw mill and alkali bypass, if applicable, at the inlet to the PM control device. (c) The three hour rolling average temperat ure shall be calculated as the average 180 successive one-minute average temperatures. (d) Periods of time when one-minute averages are not available shall be ignored when calculating three-hour rolling av erages. When one-minute averages become available, the first one-minute average is added to the previous 179 values to calculate the three-hour rolling average. (e) When the operating status of the raw mill of the in-line kiln/raw mill is changed from off to on, or from on to off the calculation of the three-hour rolling average temperature must begin anew, without considering previous recordings. (f) The calibration of all thermocouples a nd other temperature sensors shall be verified at least once every three months.

II.B.6.i.2 Recordkeeping:

The permittee shall comply with the reco rdkeeping requirements specified in 63.10 of the general provisions of 40 CFR 63, and those specified in Section I of this permit. Additionally, the permittee shall keep a log of the annual inspections of the components of the combustion system of each kiln or in-line kiln/raw mill.

II.B.6.i.3 Reporting:

The permittee shall comply with the repor ting requirements specified in 63.10 of the general provisions of 40 CFR 63, Subpa rt A, provisions of 40 CFR 63.1354, and those specified in Section I of this permit.

II.B.6.j Condition:

Emissions of Dioxins/Furans (D/F) shall be no greater than 0.20 ng per dscm (8.7 x 10 ^- 11 gr per dscf) (TEQ) corrected to seven percent oxygen or 0.40 ng per dscm (1.7 x 10 ^- 10 gr per dscf) (TEQ) corrected to seven percent oxygen, when the average of the performance test run average temperatures at th e inlet to the particulate matter control device is 204 deg. C (400 deg. F) or less. [Authority granted under 40 CFR 63 (Subpart LLL); condition originated in 40 CFR 63 (Subpart LLL)]

II.B.6.j.1 Monitoring:

(a) Frequency. Emissions shall be tested every 30 months. The source may also be tested at any time if directed by the Executive Secretary.

(b) Notification. At least 60 days be fore the test, the source shall notify the Executive Secretary of the date, time, and place of testing and provide a copy of the test protocol. The source shall attend a pretest conference if determined necessary by the Executive Secretary.

(c) Methods.

(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60, Appendix A, Method 1, and Occupational Safety

Issued December 1, 2006 Page 34 Title V Operating Permit #2300015002and Health Administration (OSHA) or Mi ne Safety and Health Administration (MSHA) approved access shall be provided to the test location.

(2) 40 CFR 60, Appendix A, Method 23 shall be used to determine the pollutant emission rate.

(3) 40 CFR 60, Appendix A, Method 2 shall be used to determine the

volumetric flow rate.

(4) Performance tests shall be conducted separately while the raw mill of

the in-line kiln/raw mill is under norma l operating conditions and while the raw mill of the in-line kiln/raw mill is not operating. If the kiln or in-line kiln/raw mill is equipped with an alkali bypass, simultaneous performance tests of the kiln

or in-line kiln/raw mill exhaust and the alkali bypass shall be performed; however, a performance test of the alkali bypass exhaust may be conducted when the raw mill of the in-line kiln/raw mill is not operating.

(5) Each performance test shall consist of three separate runs; each run

shall be conducted under the conditions that exist when the affected source is operating at the representative perform ance conditions in accordance with 40 CFR 63.7(e). The duration of each run shall be at least 3 hours, and the sample volume for each run shall be at least 2.5 dscm (90 dscf).

(6) The temperature at the inlet to the kiln or in-line kiln/raw mill PMCD, and where applicable, the temperat ure at the inlet to the alkali bypass PMCD, must be continuously recorded during the period of the Method 23 test, and the continuous temperature record(s) must be included in the performance
test report.

(7) One-minute average temperatur es shall be calculated for each minute

of each run of the test.

(8) The run average temperature must be calculated for each run, and the average of the run average temperatures must be determined and included in the performance test report and will determine the applicable temperature limit in accordance with 40 CFR 63.1344(b).

(9) If activated carbon injection is used for D/F control, the rate of activated carbon injection to the kiln or in-line kiln/raw mill exhaust, and where applicable, the rate of activated carbon injection to the alkali bypass exhaust, must be continuously recorded during the period of the Method 23 test, and the continuous injection rate record(s) mu st be included in the performance test report. In addition, the performance test re port must include the brand and type of activated carbon used during the performance test and a continuous record of either the carrier gas flow rate or the carrier gas pressure drop for the duration of the test. The run average injection rate must be calculated for each run, and the average of the run average injection rates must be determined and included in the performance test report and will determine th e applicable injection rate limit in accordance with §63.1344(c)(1).

Issued December 1, 2006 Page 35 Title V Operating Permit #2300015002(d) Calculations. The concentration sha ll be determined for each test run, and the arithmetic average of the concentrati ons measured for the three runs shall be calculated and used to determine compliance.

II.B.6.j.2 Recordkeeping:

Results of all stack testing shall be r ecorded and maintained in accordance with

the associated test method and Provision S. 1 in Section I of this permit.

II.B.6.j.3 Reporting:

The results of stack testing shall be s ubmitted to the Executive Secretary within 60 days of completion of the testing. Reports shall clearly identify results as compared to permit limits and indicate compliance status. There are no additional reporting requirements for th is provision except those specified in Section I of this permit.

II.B.6.k Condition:

Sulfur content of fuel burned shall be no greater than 1.0 lbs sulfur/MMBtu for any mixture of coal nor 0.85 pounds sulfur per million gross Btu heat input for any oil except used oil or 0.5 percent by weight for any used oil. [Authority granted under R307-401- 8(1)(a) [BACT]; condition originated in DAQE-AN0303012-06]

II.B.6.k.1 Monitoring:

Certification of fuels shall be either by permittee’s testing or test reports from the fuel marketer. Methods for determining su lfur content of coal and fuel oil shall be those methods of the American Society for Testing and Materials, UAC R307- 203-1(4)

( a ) For determining sulfur content in coal, ASTM Methods D3177-75 or

D4239-85 are to be used. ( b ) For determining sulfur content in oil, ASTM Methods D2880-71 or D4294-

89 are to be used. ( c ) For determining the gross calorific (or Btu) content of coal, ASTM Methods

D2015-77 or D3286-85 are to be used.

II.B.6.k.2 Recordkeeping:

Compliance with the above limitation shall be demonstrated by maintaining fuel receipt records showing sulfur content of the delivered fuel or maintaining records of all sulfur content testing performed on the delivered fuel.

II.B.6.k.3 Reporting:

There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.6.l Condition:

Emissions of CO shall be no greater than 13,045 tons per rolling 12-month period and 6,600 pounds per hour. [Authority granted under R307-401-8(1)(a) [BACT]; condition originated in DAQE-AN0303012-06]

II.B.6.l.1 Monitoring:

While the affected emission unit is operating, hourly CO emission rates expressed in tons per hour shall be de termined in accordance with R307-170

Issued December 1, 2006 Page 36 Title V Operating Permit #2300015002using the appropriate conversion factors. The applicable performance specification in R307-170 shall be 40 CFR 60, Appendix B, Performance Specification 6 - "Specifications and Test Procedures for Continuous Emission Rate Monitoring Systems in Stationary Sources". By the 25th day of each month

a new 12-month CO emission total for th e common stack shall be calculated as the sum of the monthly CO emission totals for each of the previous 12 months.

II.B.6.l.2 Recordkeeping:

The permittee shall keep the records spec ified in R307-170-8 and any additional records required by provision I.S.1 of this permit. These records shall be

maintained in accordance with Provision I.S.1.

II.B.6.l.3 Reporting:

The permittee shall comply with the reporting provisions in R307-170-9 and any additional reporting provisions contai ned in Section I of this permit.

The quarterly reports required in R307-170-9 are considered prompt notification of permit deviations required in Provision I.S.2.c of this permit if all information required by Provision I.S.2.c is included in the report.

II.B.6.m Condition:

Production of clinker shall be no greater than 962,265 tons per 12-month rolling period. [Authority granted under R307-401-8(1)(a) [BACT]; condition originated in DAQEAN0303012-06]

II.B.6.m.1 Monitoring:

Records required for this permit cond ition will serve as monitoring.

II.B.6.m.2 Recordkeeping:

Daily records of clinker production and k iln feed rates shall be kept for all periods of operation. By the 25th day of each month, a new 12-month total shall be calculated for clinker production using data from the previous 12 months. Records shall be kept in a supervisor log and in accordance with Provision I.S.1 of this permit.

II.B.6.m.3 Reporting:

There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.6.n Condition:

No greater than 10 percent of the kiln gases shall be routed to the Coal Grinding System (designated as 41B.BF2). [Authority granted under 40 CFR 63.8(f) (Subpart A); condition originated in Alternative Monitoring EPA Approval 11/6/02]

II.B.6.n.1 Monitoring:

Records required for this permit cond ition will serve as monitoring.

II.B.6.n.2 Recordkeeping:

Records verifying the percent of kiln gases routed to the coal grinding system shall be maintained in accordance with Provision I.S.1 of this permit and made available for review by the Executive Secretary or his representative.

Issued December 1, 2006 Page 37 Title V Operating Permit #2300015002II.B.6.n.3 Reporting:

There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.7 Conditions on Clinker Cooler (419.BF1)

II.B.7.a Condition:

Emissions of particulate matter shall be no great er than 0.10 lbs per ton (0.050 kg/Mg) of kiln feed (dry basis). [Authority granted under R307-401-8(1)(a) [BACT] & 40 CFR 63 (Subpart LLL); condition originated in 40 CFR 63 (Subpart LLL)]

II.B.7.a.1 Monitoring:

Stack testing shall be performed as specified below:

(a) Frequency. Emissions shall be tested every five (5) years, based on the date of the most recent stack test. Tests may also be required at the direction of the Executive Secretary.

(b) Notification. At least 60 days be fore the test, the source shall notify the Executive Secretary of the date, time, and place of testing and provide a copy of the test protocol. The source shall attend a pretest conference if determined necessary by the Executive Secretary.

(c) Methods.

(1) Sample Location - the emission point shall conform to the requirements of 40 CFR 60, Appendix A, Method 1, and Occupational Safety and Health Administration (OSHA) or Mi ne Safety and Health Administration (MSHA) approvable access shall be provided to the test location.

(2) Sample Method - 40 CFR 60, Appendix A, Method 5 shall be used to determine particulate matter emissions and the volumetric flow rate of the effluent gas. Each test shall consist of three separate runs. Each run shall be conducted for at least one hour, and the minimum sample volume shall be 0.85 dscm (30 dscf). The average of the th ree runs shall be used to determine compliance. The emission rate of particulate matter shall be computed for each run using the equation in 40 CFR 63.1349(b)(1).

(d) Production Rate During Testing. The production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three (3) years.

II.B.7.a.2 Recordkeeping:

Results of all stack testing shall be r ecorded and maintained in accordance with

the associated test method and Provision S. 1 in Section I of this permit.

II.B.7.a.3 Reporting:

The results of stack testing shall be s ubmitted to the Executive Secretary within 60 days of completion of the testing. Reports shall clearly identify results as compared to permit limits and indicate compliance status. There are no

Issued December 1, 2006 Page 38 Title V Operating Permit #2300015002additional reporting requirements for th is provision except those specified in Section I of this permit.

II.B.7.b Condition:

Emissions of PM 10 shall be no greater than 10.4 lbs/hr. [Authority granted under R307- 401-8(1)(a) [BACT]; condition originated in DAQE-AN0303012-06]

II.B.7.b.1 Monitoring:

(a) Stack testing shall be performed as specified below: (i) Frequency. Emissions shall be tested every three years. The source may also be tested at any time if directed by the Executive Secretary. (ii) Notification. At least 30 days before the test, the source shall notify the Executive Secretary of the date, time, and place of testing and provide a copy of the test protocol. The source shall attend a pretest conference if determined necessary by the Executive Secretary. (iii) Methods. a. Sample Location - the emission point shall conform to the requirements of 40 CFR 60, Appendi x A, Method 1, and Occupational Safety and Health Administration (OSHA) approved access shall be provided to the test location. b. For stacks in which no liquid drops are present, the following methods shall be used: 40 CFR 51, Appendix M, Methods 201 or 201a. Method 202 may be used to measure condensible particulate matter. c. For stacks in which liquid drops are present, methods to eliminate the liquid drops should be explored. If no reasonable method to eliminate the drops exists, then the following methods shall be used: 40 CFR 60, Appendix A, Method 5, 5a, 5d, or 5e as appropriate. The back half condensibles shall also be tested using a method specified by the Executive Secretary. All particulate captured shall be considered PM 10

. d. The back half condensibles shall not be used for compliance demonstration but shall be used for inventory purposes. (iv) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as determined by the appropriate methods above shall be multiplied by the volumetric flow rate and any necessary conversion factors determined by the Executive Secretary to give the results in the specified

units of the emission limitation. (v) Production Rate During Testing. The production rate during all compliance testing shall be no less than 90% of the maximum production achieved in the previous three (3) years. (b) Optical density shall be used as an indicator to provide reasonable assurance of compliance with the PM 10 emission limitation as specified below. (i) Measurement Approach: Opacity sh all be determined using a continuous opacity monitor (COM) located in th e exhaust stack. The opacity shall be mathematically converted to units of optical density. (ii) Indicator Range: An excursion is defined as a 24-hour block average optical density in excess of 0.046 excl uding periods of st artup, shutdown, or malfunction. Excursions trigger an inspection, corrective action, and a reporting requirement. Provision II.B.7.b.1(b)(ii) of this permit does not constitute a waiver, or a shield against enforcement, of Provision II.B.7.c of this permit.

Issued December 1, 2006 Page 39 Title V Operating Permit #2300015002Once every three years, during the stack test required in (a) above, the permittee shall acquire new test data to evaluate or update the excursion optical density value. The procedure for collecting new test data is described in a reviewer comment at the end of this permit. (iii) Performance Criteria: a. Data Representativeness: The COM shall be installed in a representative location in the exhaus t stack and shall be calibrated, maintained, and operated in accordance with 40 CFR Part 60 Appendix B Performance Specification 1 and R307-170. b. QA/QC Practices and Criteria: The COM shall be calibrated, maintained, and operated in accordance with 40 CFR Part 60 Appendix B Performance Specification 1, R307-170, and the

manufacturer’s written recommendations. c. Monitoring Frequency: Opacity shall be monitored continuously and a data point recorded electronically every 10 seconds. d. Data Collection Procedure: The 10-second opacity data shall be used to calculate 6-minute opacity averages. The 6-minute opacity averages shall be mathematically converted to units of optical density. The 6-minute optical density values shall be averaged over a 1-hour block. The 1-hour optical density averages shall be used to calculate a 24-hour block average. The 24-hour block average optical density shall be recorded and stored electronically. e. Averaging Period: 24-hour block average.

II.B.7.b.2 Recordkeeping:

Results of all stack testing shall be r ecorded and maintained in accordance with the associated test method and Provision I.S.1 of this permit.

Records of the 24-hour block average optical density values shall be maintained in accordance with Provision I.S.1 of this permit. In addition, the permittee shall

maintain records of: a) all test data from the most recent stack test and the calculations that were used to evaluate or revise the excursion optical density value. b) all continuous opacity monitor (COM) parameters, performance test measurements, all COM performance evaluations, all COM calibration checks, all COM adjustments and maintenance, and all other information required by R307-170 in a permanent form suitable for inspection. c) the occurrence and duration of any excursion, corrective actions taken, and any other supporting information re quired to be maintained under 40 CFR 64 (such as data used to document the adequacy of monitoring, or records of monitoring maintenance or corrective actions). Instead of paper records, the permittee may main tain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. (40 CFR 64.9(b))

II.B.7.b.3 Reporting:

In addition to the reporting requirements in Provision I.S.2 of this permit, (a) Monitoring reports shall include, at a minimum, the following information, as applicable:

Issued December 1, 2006 Page 40 Title V Operating Permit #2300015002(i) Summary information on the number, duration and cause (including unknown cause, if applicable) of excursions or exceedances, as applicable, and the corrective actions taken; (40 CFR 64.9(a)(2)(i)) (ii) Summary information on the num ber, duration and cause (including unknown cause, if applicable) for monitor downtime incidents (other than downtime associated with zero and span or other daily calibration checks, if applicable). (40 CFR 64.9(a)(2)(ii)) (b) The results of stack testing shall be submitted to the Executive Secretary within 60 days of completion of the t esting. Reports shall clearly identify results as compared to permit limits and indicate compliance status.

II.B.7.c Condition:

Visible emissions shall be no greater than 10 percent opacity. [Authority granted under 40 CFR 63 (Subpart LLL); condition originated in DAQE-AN0303012-06]

II.B.7.c.1 Monitoring:

The permittee shall calibrate, maintain and operate a continuous monitoring system for measuring the opacity of emi ssions discharged to the atmosphere in accordance with R307-170 and 40 CFR 63.8 (Subpart A), and shall record the output of the system. The output shall be reviewed at least monthly for compliance with the opacity limit; complia nce is to be based on the percent opacity averaged over six consecutive minutes.

II.B.7.c.2 Recordkeeping:

Results of opacity observations shall be recorded and maintained as required in R307-170 and as described in Provision I.S.1 of this permit.

II.B.7.c.3 Reporting:

The permittee shall comply with the reporting provisions in R307-170-9 and any additional reporting provisions contai ned in Section I of this permit.

The quarterly reports required in R307-170-9 are considered prompt notification of permit deviations required in Provision I.S.2.c of this permit if all information required by Provision I.S.2.c is included in the report.

II.B.8 Conditions on Finish Mill (514.BF2)

II.B.8.a Condition:

Visible emissions shall be no greater than 10 percent opacity. [Authority granted under40 CFR 63, Subpart LLL; condition originated in 40 CFR 63 (Subpart LLL) & DAQEAN0303012-06]

II.B.8.a.1 Monitoring:

A. The permittee shall monitor opacity by conducting daily visual emissions observations of the mill sweep and air separator PMCD in accordance with the procedures of 40 CFR 60, Appendix A, Method 22. The Method 22 test

shall be conducted while the affected source is operating at the representative performance conditions. The duration of the Method 22 test shall be 6 minutes. If visible emissions are observed during any Method 22 visible emissions test, the permittee must:

Issued December 1, 2006 Page 41 Title V Operating Permit #2300015002(1) Initiate, within one-hour, the corr ective actions specified in the site specific operating and maintenance plan developed in accordance with condition II.B.1.g of this permit; and (2) Within 24 hours of the end of the Method 22 test in which visible emissions were observed, conduct a followup Method 22 test of each stack from which visible emissions were observed during the previous Method 22 test. If visible emissions are observed during the followup Method 22 test from any stack from which visible emissions were observed during the previous Method 22 test, conduct a visual opacity test of each stack from which emissions were observed during the follow up Method 22 test in accordance with 40 CFR 60, Appendix A, Method 9. The duration of the Method 9 test shall be 30 minutes. [origin: 40 CFR 63.1350(e) and Table 1 to 63.1350] B. In lieu of the daily visual emissions testing required in paragraph A. above, the permittee may choose to install a continuous opacity monitor (COM) or bag leak detection system (BLDS). (1) If the permittee chooses to install a COM, it must be installed at the outlet of the PM control device of the mill. The COM must be installed, maintained, calibrated, and operated as required by 40 CFR 60, Appendix B, PS-1-'Specifications and Test Procedures for Continuous Opacity Monitoring Systems in Stationary Sources', 40 CFR 63.8 (Subpart A), and R307-170. To remain in compliance, the opacity must

be maintained such that the 6-mi nute average opacity for any 6-minute block period does not exceed 10 percen t. If the average opacity for any 6-minute block period exceeds 10 percent, this shall constitute a violation of the standard. COM output shall be recorded. The output shall be reviewed at least monthly for compliance. (2) If the permittee chooses to install a BLDS, the following requirements apply to each BLDS: (a) The BLDS must be certified by the manufacturer to be capable of detecting PM emissions at concentr ations of 10 milligrams per actual cubic meter (0.0044 grains per actual cubic foot) or less. "Certify"

shall mean that the instrument manuf acturer has tested the instrument on gas streams having a range of particle size distributions and confirmed by means of valid filterable PM tests that the minimum detectable concentration limit is at or below 10 milligrams per actual cubic meter (0.0044 grains per actual cubic foot) or less. (b) The sensor on the BLDS must provide output of relative PM

emissions. (c) The BLDS must have an alarm th at will activate automatically when it detects a significant increase in relative PM emissions greater than a preset level. (d) The presence of an alarm condition should be clearly apparent to facility operating personnel. (e) For a positive-pressure fabric filter, each compartment or cell must have a bag leak detector. For a negative-pressure or induced-air fabric filter, the bag leak detector must be installed downstream of the fabric filter. If multiple bag leak detectors are required (for either type of fabric filter), detectors may share the system instrumentation

and alarm.

Issued December 1, 2006 Page 42 Title V Operating Permit #2300015002(f) All BLDS must be installed, operated, adjusted, and maintained so that they are based on the manufacturer's written specifications and

recommendations. (g) The baseline output of the system must be established as follows: (i) Adjust the range and the averaging period of the device; and (ii) Establish the alarm set points and the alarm delay time. (h) After initial adjustment, the range, averaging period, alarm set points, or alarm delay time may not be adjusted except as specified in the operations and maintenance plan required by 40 CFR 63.1350(a). In no event may the range be increased by more than 100 percent or decreased by more than 50 percent over a 1 calendar year period unless a responsible official as defined in R307-415-3 certifies in writing to the Executive S ecretary that the fabric filter has been inspected and found to be in good operating condition. (i) The permittee must maintain and operate the fabric filter such that the bag leak detector alarm is not activated and alarm condition does not exist for more than 5 percent of the total operating time in a 6- month block period. Each time the alarm activates, alarm time will be counted as the actual amount of time taken by the owner or operator to initiate corrective actions . If inspection of the fabric filter demonstrates that no corrective actions are necessary, no alarm time

will be counted. [origin: 40 CFR 63.1350(m)] C. Once every five years, the permittee shall demonstrate compliance with the opacity limit by conducting a test in accordance with 40 CFR 60, Appendix A, Method 9. The performance test shall be conducted under normal operating conditions in accordance with 40 CFR 63.7(e). The maximum 6- minute average opacity exhibited during the test period shall be used to determine whether the affected source is in compliance with the standard. The duration of the Method 9 performance test shall be 3 hours (30 6-minute averages), except that the duration of the Method 9 performance test may be reduced to 1 hour if the conditions of paragraphs (i) and (ii) apply: (i) There are no individual readings greater than 10 percent opacity; (ii) There are no more than three readings of 10 percent for the first 1-hour period. (origin: 40 CFR 63.1349(b)(2), 40 CFR 63.1349(c))

At least 60 days before the perform ance test, the source shall notify the Executive Secretary of the date, time, and place of testing and provide a copy of the test protocol. The source shall attend a pretest conference if determined necessary by the Executive S ecretary. [origin: 40 CFR 63.9(e) via 40 CFR 63.1353(b)(2), (3)]

II.B.8.a.2 Recordkeeping:

The permittee shall maintain files of all information (including all reports and notifications) required by this condition in a form suitable and readily available for expeditious inspection and review. Th ese files shall be retained for at least five years following the date of each occurrence, measurement, maintenance, corrective action, report or record. At a minimum, the most recent two years of

data shall be retained on site. The remain ing three years of data may be retained off site. The files may be maintained on microfilm, on a computer, on floppy

Issued December 1, 2006 Page 43 Title V Operating Permit #2300015002disks, on magnetic tape, or on microfiche . Requirements of Provision I.S.1 of this permit also apply. [origin: 40 CFR 63.1355]

Additionally, records of visual emission observations and visual opacity tests required by 40 CFR 60, Appendix A, Met hods 22 and 9 shall be maintained in

accordance with Provision I.S.1 of this permit if a COM or BLDS is not used.

If the COM option is used, results of op acity observations from the COM shall be recorded and maintained as required in R307-170, 40 CFR 63.10(c), and as described in Provision I.S.1 of this permit.

If the BLDS monitoring option is chosen, the following additional records shall be maintained in accordance with Provision I.S.1 of this permit:

(1) The permittee shall continuously record the output from the BLDS during periods of normal operation. Normal operation does not include periods when the BLDS is being maintained or during startup, shutdown or

malfunction. (2) Alarm times, as defined in the above monitoring, shall be recorded.

II.B.8.a.3 Reporting:

In addition to the reporting requirements of Provision I.S.1 of this permit, the reporting requirements of R307-170, 40 CFR 63.10(e), and 40 CFR 63.1354 also apply if a continuous monitoring method is used.

The five-year performance test results sh all be documented in complete test reports that contain the information required by paragraphs (i) through (x), as

well as all other relevant information. The plan to be followed during testing

shall be made available to the Executive S ecretary prior to testing, if requested. (i) A brief description of the process and the air pollution control system; (ii) Sampling location description(s); (iii) A description of sampling and analytical procedures and any modifications to standard procedures; (iv) Test results; (v) Quality assurance procedures and results; (vi) Records of operating conditions during the test, preparation of standards, and calibration procedures; (vii) Raw data sheets for field sampling and field and laboratory analyses; (viii) Documentation of calculations; (ix) All data recorded and used to establish parameters for compliance monitoring; and (x) Any other information required by the test method. (origin: 40 CFR 63.1349(a))

II.B.9 Conditions on Finish Mill Separator (514.BF1)

II.B.9.a Condition:

Visible emissions shall be no greater than 10 percent opacity. [Authority granted under40 CFR 63, Subpart LLL; condition originated in 40 CFR 63 (Subpart LLL) & DAQEAN0303012-06]

Issued December 1, 2006 Page 44 Title V Operating Permit #2300015002II.B.9.a.1 Monitoring:

A. The permittee shall monitor opacity by conducting daily visual emissions observations of the mill sweep and air separator PMCD in accordance with the procedures of 40 CFR 60, Appendix A, Method 22. The Method 22 test

shall be conducted while the affected source is operating at the representative performance conditions. The duration of the Method 22 test shall be 6 minutes. If visible emissions are observed during any Method 22 visible emissions test, the permittee must: (1) Initiate, within one-hour, the corr ective actions specified in the site specific operating and maintenance plan developed in accordance with condition II.B.1.g of this permit; and (2) Within 24 hours of the end of the Method 22 test in which visible emissions were observed, conduct a followup Method 22 test of each stack from which visible emissions were observed during the previous Method 22 test. If visible emissions are observed during the followup Method 22 test from any stack from which visible emissions were observed during the previous Method 22 test, conduct a visual opacity test of each stack from which emissions were observed during the follow up Method 22 test in accordance with 40 CFR 60, Appendix A, Method 9. The duration of the Method 9 test shall be 30 minutes. [origin: 40 CFR 63.1350(e) and Table 1 to 63.1350] B. In lieu of the daily visual emissions testing required in paragraph A. above, the permittee may choose to install a continuous opacity monitor (COM) or bag leak detection system (BLDS). (1) If the permittee chooses to install a COM, it must be installed at the outlet of the PM control device of the mill. The COM must be installed, maintained, calibrated, and operated as required by 40 CFR 60, Appendix B, PS-1-'Specifications and Test Procedures for Continuous Opacity Monitoring Systems in Stationary Sources', 40 CFR 63.8 (Subpart A), and R307-170. To remain in compliance, the opacity must

be maintained such that the 6-mi nute average opacity for any 6-minute block period does not exceed 10 percen t. If the average opacity for any 6-minute block period exceeds 10 percent, this shall constitute a violation of the standard. COM output shall be recorded. The output shall be reviewed at least monthly for compliance. (2) If the permittee chooses to install a BLDS, the following requirements apply to each BLDS: (a) The BLDS must be certified by the manufacturer to be capable of detecting PM emissions at concentr ations of 10 milligrams per actual cubic meter (0.0044 grains per actual cubic foot) or less. "Certify"

shall mean that the instrument manuf acturer has tested the instrument on gas streams having a range of particle size distributions and confirmed by means of valid filterable PM tests that the minimum detectable concentration limit is at or below 10 milligrams per actual cubic meter (0.0044 grains per actual cubic foot) or less. (b) The sensor on the BLDS must provide output of relative PM

emissions. (c) The BLDS must have an alarm th at will activate automatically when it detects a significant increase in relative PM emissions greater than a preset level.

Issued December 1, 2006 Page 45 Title V Operating Permit #2300015002(d) The presence of an alarm condition should be clearly apparent to facility operating personnel. (e) For a positive-pressure fabric filter, each compartment or cell must have a bag leak detector. For a negative-pressure or induced-air fabric filter, the bag leak detector must be installed downstream of the fabric filter. If multiple bag leak detectors are required (for either type of fabric filter), detectors may share the system instrumentation

and alarm. (f) All BLDS must be installed, operated, adjusted, and maintained so that they are based on the manufacturer's written specifications and

recommendations. (g) The baseline output of the system must be established as follows: (i) Adjust the range and the averaging period of the device; and (ii) Establish the alarm set points and the alarm delay time. (h) After initial adjustment, the range, averaging period, alarm set points, or alarm delay time may not be adjusted except as specified in the operations and maintenance plan required by 40 CFR 63.1350(a). In no event may the range be increased by more than 100 percent or decreased by more than 50 percent over a 1 calendar year period unless a responsible official as defined in R307-415-3 certifies in writing to the Executive S ecretary that the fabric filter has been inspected and found to be in good operating condition. (i) The permittee must maintain and operate the fabric filter such that the bag leak detector alarm is not activated and alarm condition does not exist for more than 5 percent of the total operating time in a 6- month block period. Each time the alarm activates, alarm time will be counted as the actual amount of time taken by the owner or operator to initiate corrective actions . If inspection of the fabric filter demonstrates that no corrective actions are necessary, no alarm time

will be counted. [origin: 40 CFR 63.1350(m)] C. Once every five years, the permittee shall demonstrate compliance with the opacity limit by conducting a test in accordance with 40 CFR 60, Appendix A, Method 9. The performance test shall be conducted under normal operating conditions in accordance with 40 CFR 63.7(e). The maximum 6- minute average opacity exhibited during the test period shall be used to determine whether the affected source is in compliance with the standard. The duration of the Method 9 performance test shall be 3 hours (30 6-minute averages), except that the duration of the Method 9 performance test may be reduced to 1 hour if the conditions of paragraphs (i) and (ii) apply: (i) There are no individual readings greater than 10 percent opacity; (ii) There are no more than three readings of 10 percent for the first 1-hour period. (origin: 40 CFR 63.1349(b)(2), 40 CFR 63.1349(c))

At least 60 days before the perform ance test, the source shall notify the Executive Secretary of the date, time, and place of testing and provide a copy of the test protocol. The source shall attend a pretest conference if determined necessary by the Executive S ecretary. [origin: 40 CFR 63.9(e) via 40 CFR 63.1353(b)(2), (3)]

Issued December 1, 2006 Page 46 Title V Operating Permit #2300015002II.B.9.a.2 Recordkeeping:

The permittee shall maintain files of all information (including all reports and notifications) required by this condition in a form suitable and readily available for expeditious inspection and review. Th ese files shall be retained for at least five years following the date of each occurrence, measurement, maintenance, corrective action, report or record. At a minimum, the most recent two years of

data shall be retained on site. The remain ing three years of data may be retained off site. The files may be maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or on microfiche . Requirements of Provision I.S.1 of this permit also apply. [origin: 40 CFR 63.1355]

Additionally, records of visual emission observations and visual opacity tests required by 40 CFR 60, Appendix A, Met hods 22 and 9 shall be maintained in

accordance with Provision I.S.1 of this permit if a COM or BLDS is not used.

If the COM option is used, results of op acity observations from the COM shall be recorded and maintained as required in R307-170, 40 CFR 63.10(c), and as described in Provision I.S.1 of this permit.

If the BLDS monitoring option is chosen, the following additional records shall be maintained in accordance with Provision I.S.1 of this permit:

(1) The permittee shall continuously record the output from the BLDS during periods of normal operation. Normal operation does not include periods when the BLDS is being maintained or during startup, shutdown or

malfunction. (2) Alarm times, as defined in the above monitoring, shall be recorded.

II.B.9.a.3 Reporting:

In addition to the reporting requirements of Provision I.S.1 of this permit, the reporting requirements of R307-170, 40 CFR 63.10(e), and 40 CFR 63.1354 also apply if a continuous monitoring method is used.

The five-year performance test results sh all be documented in complete test reports that contain the information required by paragraphs (i) through (x), as

well as all other relevant information. The plan to be followed during testing

shall be made available to the Executive S ecretary prior to testing, if requested. (i) A brief description of the process and the air pollution control system; (ii) Sampling location description(s); (iii) A description of sampling and analytical procedures and any modifications to standard procedures; (iv) Test results; (v) Quality assurance procedures and results; (vi) Records of operating conditions during the test, preparation of standards, and calibration procedures; (vii) Raw data sheets for field sampling and field and laboratory analyses; (viii) Documentation of calculations;

Issued December 1, 2006 Page 47 Title V Operating Permit #2300015002(ix) All data recorded and used to establish parameters for compliance monitoring; and (x) Any other information required by the test method. (origin: 40 CFR 63.1349(a))

II.B.10 Conditions on Materials Handling Operation (MHO)

II.B.10.a Condition:

Visible emissions shall be no greater than 10 percent opacity from each affected unit. [Authority granted under 40 CFR 63, Subpart LLL; condition originated in 40 CFR 63 (Subpart LLL)]

II.B.10.a.1 Monitoring:

(a) Monitoring of visible emissions shall be performed as follows: (1) The permittee shall conduct a monthly 1-minute visible emissions test of each affected source in accordance with 40 CFR 60, Appendix A,

Method 22. The test must be conducted while the affected source is in operation. (2) If no visible emissions are observed in six consecutive monthly tests for any affected source, the permittee may decrease the frequency of testing from monthly to semi-annually for that affected source. If visible emissions are observed during any sem i-annual test, the permittee must resume testing of that affected source on a monthly basis and maintain

that schedule until no visible emissions are observed in six consecutive monthly tests. (3) If no visible emissions are observed during the semi-annual test for any affected source, the permittee may decrease the frequency of testing from semi-annually to annually for that affected source. If visible emissions are observed during any annual test, the permittee shall resume testing of that affected source on a monthly basis and maintain that schedule until no visible emissions are observed in six consecutive monthly tests. (4) If visible emissions are observed during any Method 22 test, the permittee shall conduct a 6-minute test of opacity in accordance with 40 CFR 60, Appendix A, Method 9. The Method 9 test must begin within one hour of any observation of visible emissions. (5) The requirement to conduct Method 22 visible emissions monitoring under this condition shall not apply to any totally enclosed conveying system transfer point, regardless of the location of the transfer point. "Totally enclosed conveying system transfer point" shall mean a conveying system transfer point that is enclosed on all sides, top, and bottom. The enclosures for these transfer points shall be operated and

maintained as total enclosures on a continuing basis in accordance with the facility operations and maintenance plan. (6) If any partially enclosed or unenclosed conveying system transfer point is located in a building, the permittee shall have the option to conduct a Method 22 visible emissions monitoring test according to the requirements of paragraphs 1 through 4 of this condition for each such conveying system transfer point located within the building, or for the building itself, according to para graph 7 of this condition. (7) If visible emissions from a building are monitored, the requirements of paragraphs 1 through 4 of this condition apply to the monitoring of the

Issued December 1, 2006 Page 48 Title V Operating Permit #2300015002building, and the permittee shall also test visible emissions from each side, roof and vent of the building for at least 1 minute. The test must be conducted under normal oper ating conditions. (b) Once every five years, the permittee shall demonstrate compliance with the opacity limit by conducting a test in accordance with Method 9 of appendix A to 40 CFR Part 60. The performance test shall be conducted under normal operating conditions in accordance with 40 CFR 63.7(e). The maximum 6- minute average opacity exhibited during the test period shall be used to determine whether the affected source is in compliance with the standard. The duration of the Method 9 performance test shall be 3 hours (30 6-minute averages), except that the duration of the Method 9 performance test may be reduced to 1 hour if the conditions of paragraphs (i) and (ii) apply: (i) There are no individual readings greater than 10 percent opacity; (ii) There are no more than three readings of 10 percent for the first 1-hour period. (origin: 40 CFR 63.1349(b)(2), 40 CFR 63.1349(c))

At least 60 days before the perform ance test, the source shall notify the Executive Secretary of the date, time, and place of testing and provide a copy of the test protocol. The source shall attend a pretest conference if determined necessary by th e Executive Secretary. [origin: 40 CFR 63.9(e) via 40 CFR 63.1353(b)(2), (3)]

II.B.10.a.2 Recordkeeping:

The permittee shall maintain files of all information (including all reports and notifications) required by this condition in accordance with Provision I.S.1 of this permit and in a form suitable and readily available for expeditious inspection and

review. These files shall be retained for at least five years following the date of each occurrence, measurement, maintenance, corrective action, report or record. At a minimum, the most recent two years of data shall be retained on site. The remaining three years of data may be retained off site. The files may be maintained on microfilm, on a computer, on floppy disks, on magnetic tape, or

on microfiche.

In addition, results from opacity observations and all data required by 40 CFR 60, Appendix A, Method 22 and 9 sha ll be recorded and maintained in accordance with Provision I.S.1 of this permit. (origin: 40 CFR 63.1355)

II.B.10.a.3 Reporting:

In addition to the reporting requirements sp ecified in Section I of this permit, performance test results shall be documented in complete test reports that contain the information required by paragraphs (i) through (x), as well as all other relevant information. The plan to be followed during testing shall be made available to the Executive Secretary prior to testing, if requested. (i) A brief description of the process and the air pollution control system; (ii) Sampling location description(s); (iii) A description of sampling and analytical procedures and any modifications to standard procedures; (iv) Test results; (v) Quality assurance procedures and results;

Issued December 1, 2006 Page 49 Title V Operating Permit #2300015002(vi) Records of operating conditions during the test, preparation of standards, and calibration procedures; (vii) Raw data sheets for field sampling and field and laboratory analyses; (viii) Documentation of calculations; (ix) All data recorded and used to establish parameters for compliance monitoring; and (x) Any other information required by the test method. (origin: 40 CFR 63.1349(a))

II.B.11 Conditions on Limestone Bypass System (LBS)

II.B.11.a Condition:

Visible emissions shall be no greater than 10 percent opacity. [Authority granted under 40 CFR 60.672(b) (Subpart OOO); conditi on originated in DAQE-AN0303012-06]

II.B.11.a.1 Monitoring:

A visual observation of each affected emission unit shall be performed on a weekly basis by an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The individual is not required to be a certified visible emissions observer (VEO). If any visible emissions are observed, an opacity determination of that emission unit shall be performed by a certified VEO in accordance with 40 CFR 60, Appendix A, Method 9 within 24 hours of the initial observation. For each affected emission unit, if no visible emissions are observed for eight consecutive weeks the observation frequency shall be reduced to a monthly basis. If visible emissions are observed during any monthly observation the frequency shall revert back to a weekly basis.

II.B.11.a.2 Recordkeeping:

Records of visual observations perform ed and data required by 40 CFR 60, Appendix A, Method 9 for each determination shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.11.a.3 Reporting:

There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.11.b Condition:

Throughput shall be no greater than 60,000 tons per 12-month rolling period. [Authority granted under R307-401-8(1)(a) [BACT]; condition originated in DAQE-AN0303012- 06]

II.B.11.b.1 Monitoring:

Records required for this permit cond ition will serve as monitoring.

II.B.11.b.2 Recordkeeping:

Daily records of limestone bypass throu ghput shall be kept for all periods of operation. By the 25th day of each mo nth, a new 12-month total shall be calculated using data from the previous 12 months. Records shall be kept in a supervisor log and in accordance with Provision I.S.1 of this permit

Issued December 1, 2006 Page 50 Title V Operating Permit #2300015002II.B.11.b.3 Reporting:

There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.11.c Condition:

Permittee shall operate water sprays or du st suppression sprays to control fugitive emissions. The sprays shall operate whenev er dry conditions warrant or as determined necessary by the Executive Secret ary. Sprays shall not be required during periods of freezing temperatures. [Authority granted under R307-401-8(1)(a) [BACT]; condition originated in DAQE-AN0303012-06]

II.B.11.c.1 Monitoring:

Visual inspections of the water spray syst em(s) shall be made weekly to ensure proper operating condition.

II.B.11.c.2 Recordkeeping:

An operator’s log shall be maintained of all monitoring provisions listed above. Records of water spray system inspectio ns shall be kept for all periods of operation and the ambient temperature sh all be recorded any time water should be applied but can not be due to freezing conditions.

II.B.11.c.3 Reporting:

There are no reporting requirements for th is provision except those specified in Section I of this permit.

II.B.12 Conditions on Belt Conveyor Transfer Baghouse (311.BC1)

II.B.12.a Condition:

The permittee shall notify the Executive Secretar y in writing when the installation of new equipment in the affected unit has been completed and is operational, as an initial compliance inspection is required. To ensu re proper credit when notifying the Executive Secretary, send your correspondence to th e Executive Secretary, attn: Compliance

Section.

If installation has not been completed with in eighteen months from the date of the approval order listed as "origin" for this condition, the Executive Secretary shall be notified in writing on the status of the insta llation. At that time, the Executive Secretary shall require documentation of the continuous installation of the operation and may revoke the AO in accordance with R307-401-18, UAC. [Authority granted under R307- 401-18; condition originated in DAQE-AN0303012-06]

II.B.12.a.1 Monitoring:

Records required for this permit cond ition will serve as monitoring.

II.B.12.a.2 Recordkeeping:

As applicable, the permittee shall mainta in a copy of each notification required by this permit condition in accordance with Provision I.S.1 of this permit.

II.B.12.a.3 Reporting:

There are no reporting requirements for th is provision except those specified in Section I of this permit.

Issued December 1, 2006 Page 51 Title V Operating Permit #2300015002II.C. Emissions Trading.

(R307-415-6a(10))

Not applicable to this source.

II.D. Alternative Operating Scenarios.

(R307-415-6a(9))

Not applicable to this source.



## Section III: PERMIT SHIELD

The following requirements have been determined to be not applicable to this source in accordance with Provision I.M, Permit Shield:

III.A. 40 CFR 63.1349(b)(3), 63.1350(f), Subpart LLL (NESHAP from the Portland Cement Manufacturing Industry)

This regulation is not applicable to the Coal Grinding System (41B.BF2) because EPA granted a waiver in a letter dated November 6, 2002 from Martin Hestmark, EPA, to Robert Vantuyl, Ash Grove. The waiver is contingent on Ash Grove's compliance with Conditions II.B.6.i, II.B.6.j, II.B.4.b, and II.B.6.n. of this permit.

III.B. 40 CFR, Part 60, Subpart F (NSPS / Standards of Performance for Portland Cement Plants)

This regulation is not applicable to the permitted source (Source-wide) because all Subpart F affected facilities are covered by 40 CFR 63 Subpart LLL.

III.C. 40 CFR, Part 60, Subpart OOO (NSPS / Standard s of Performance for Nonmetallic Mineral Processing Plants)

This regulation is not applicable to the Stati onary Crusher (211.BF1) because it was constructed in 1981, prior to the Subpart OOO applicability date of August 31, 1 983. [40 CFR 60.670(e)]

III.D. 40 CFR, Part 60, Subpart OOO (NSPS / Standard s of Performance for Nonmetallic Mineral Processing Plants)

This regulation is not applicable to the Ra w Material Transfer (211.BF2) because it was constructed in 1981, prior to the Subpart OOO applicability date of A ugust 31, 1983. [40 CFR 60.670(e)]

III.E. 40 CFR 63.1350(c), 63.1350(d), Subpart LLL (NESHAP from the Portland Cement Manufacturing Industry)

This regulation is not applicable to the Coal Grinding System (41B.BF2) because it is not an affected source as defined in 40 CFR 63.1340. The coal mill is regulated by 40 CFR 60 Subpart

Y.

Issued December 1, 2006 Page 52 Title V Operating Permit #2300015002

## Section IV: ACID RAIN PROVISIONS.

This source is not subject to Title IV. This section is not applicable.

Issued December 1, 2006 Page 53 Title V Operating Permit #2300015002

## REVIEWER COMMENTS

This operating permit incorporates all appli cable requirements contained in the following

documents:

DAQE-AN0303012-06 date d July 25, 2006

1. Comment on an item originating in DAQE-AN0303012-06 regarding Kiln & Pre-Calciner and Raw Mill (Unit 317.BF1)

Stack test for PM 10 : This unit is subject to CAM in the renewal permit. As per 40 CFR 64.5(d), CAM monitoring satisfies the requirement in 40 CFR 70.6(a)(3)(i)(B) for periodic monitoring, but the PM 10 stack test frequency specified in the AO remains an applicable requirement in Title V. [Comment last updated on 6/29/2006]

2. Comment on an item originating in this pe rmit regarding Kiln & Pre-Calciner and Raw Mill (Unit 317.BF1) Additional data collection for optical density (OD) evaluation: The following applies to the collection of additional data during th e 3-year kiln stack tests to be used for evaluating or updating the excursion OD value: 1. Before obtaining data from COMS, the accu racy and reliability of the COMS shall be ensured. At a minimum, the operator sh all inspect and verify proper operation of the monitor, clean the optical windows, remove any accumulated material from the monitor flanges, adjust the monitor calibrati on to eliminate any drift or offsets, and reset zero compensation, if appropriate. The operator shall also conduct a clear path calibration of the opacity monitor within 1 month prior to the test and a performance audit using external calibrated filters. 2. Run at least three paired-runs or six consecutive runs for at least 1 hour each according to EPA Method 17, Method 5 or ASTM D6831-02. To be acceptable, each paired run result shall be within ±2 .5 mg/acm of their average. To be acceptable, each consecutive run shall be w ithin ±3.0 mg/acm of the average. Runs shall be rejected that do not meet the QA sp ecification. All test run results that meet the QA requirement shall be used to establish the ODstd. 3. During each run, the feed rate shall be recorded. Tests shall be conducted at steady state conditions ( ≤ ±10% raw material input variation).

4. Calculate the emission rate in lb/hr an d mg/acm. The emission rate shall be less than the permit limit for all runs.

5. Convert the emission limit in lb/hr to the equivalent PM concentration at actual stack conditions using the measured efflue nt flow rate, stack temperature, stack pressure, and effluent moisture concentrations. 6. Average the 6-minute average optical density readings that correspond to the duration of each acceptable PM run. In the event of COMS malfunction during the test run, the test shall be terminated. Th e variation in the optical density during the

test run shall be ≤ 0.009 OD (2% opacity), otherwise additional test runs shall be

conducted. 7. Calculate the optical density equivalent to the standard for each valid test run. Average all of the results to determin e the new value of ODstd. Compare the

Issued December 1, 2006 Page 54 Title V Operating Permit #2300015002ODstd to 0.097 (20% opacity) and use 0.67ODstd or 0.097, whichever is most restrictive. [Comment last updated on 3/29/2006]

3. Comment on an item originating in DAQE-AN0303012-06 regarding Clinker Cooler (Unit 419.BF1)

Stack test for PM 10 : This unit is subject to CAM in the renewal permit. As per 40 CFR 64.5(d), CAM monitoring satisfies the requirement in 40 CFR 70.6(a)(3)(i)(B) for periodic monitoring, but the PM 10 stack test frequency specified in the AO remains an applicable requirement in Title V. [Comment last updated on 6/29/2006]

4. Comment on an item originating in this permit regarding Clinker Cooler (Unit 419.BF1) Additional data collection for optical density (OD) evaluation: The following applies to the collection of additional data during th e 3-year clinker cooler stack tests to be used for evaluating or updating the excursion optical density (OD) value: 1. Before obtaining data from COMS, the accu racy and reliability of the COMS shall be ensured. At a minimum, the operator sh all inspect and verify proper operation of the monitor, clean the optical windows, remove any accumulated material from the monitor flanges, adjust the monitor calibrati on to eliminate any drift or offsets, and reset zero compensation, if appropriate. The operator shall also conduct a clear path calibration of the opacity monitor within 1 month prior to the test and a performance audit using external calibrated filters. 2. Run at least three paired-runs or six co nsecutive runs for at least 1 hour each using EPA Method 17, Method 5 or ASTM D6831-02. To be acceptable, each paired run result shall be within ±2.5 mg/acm of their average. To be acceptable, each consecutive run shall be within ±3.0 mg/acm of the average. Reject those runs that do not meet the QA specification. All test run results that meet the QA requirement

shall be used to establish the ODstd. 3. During each run, the feed rate shall be recorded. Tests shall be conducted at steady state conditions ( ≤ ±10% raw material input variation).

4. Calculate the emission rate in lb/hr an d mg/acm. The emission rate shall be less than the permit limit for all runs.

5. Convert the emission limit in lb/hr to the equivalent PM concentration at actual stack conditions using the measured efflue nt flow rate, stack temperature, stack pressure, and effluent moisture concentrations. 6. Average the 6-minute average optical density readings that correspond to the duration of each acceptable PM run. In the event of COMS malfunction during the test run, the test shall be terminated. Th e variation in the optical density during the

test run shall be ≤ 0.009 OD (2% opacity), otherwise additional test runs shall be

conducted. 7. Calculate the optical density equivalent to the standard for each valid test run. Average all of the results to determin e the new value of ODstd. Compare the ODstd to 0.046 (10% opacity) and use the most restrictive value. [Comment last updated on 3/01/2006]

5. Comment on an item originating in this permit regarding Coal Grinding System (Unit 41B.BF2) PM Test Frequency: A PM test frequency of five (5) years has been specified due to a low potential for noncompliance with the partic ulate standard on the thermal dryer. The low potential is demonstrated by previous st ack test results. Results and percentage of limit from previous tests are as follows:

Issued December 1, 2006 Page 55 Title V Operating Permit #2300015002September 2005: 0.0051 gr/dscf PM (16.5%) May 2002: 0.00079 gr/dscf PM (2.6%) [Comment last updated on 3/29/2006]

6. Comment on an item originating in DAQE-AN0303011-05 regarding Limestone Bypass System (Unit LBS) Removal of notice requirement: The permittee submitted notice to DAQ that the

referenced emission unit has been installe d in a letter dated 12/7/05, and received 12/12/05. The installation notice requirement for this unit has now been fulfilled, and the requirement has been removed from the permit. [Comment last updated on 6/22/2006]

7. Comment on an item originating in DAQE-AN0303011-05 regarding Limestone Silo & Belt (Unit 512.BF2 and 3) Removal of notice requirement: The permittee submitted notice to DAQ that the

referenced emission unit has been installe d in a letter dated 12/7/05, and received 12/12/05. The installation notice requirement for this unit has now been fulfilled, and the requirement has been removed from the permit. [Comment last updated on 6/22/2006]

8. Comment on an item originating in DAQE-AN0303011-05 regarding East Clinker Belt (Unit 419.BF4) Removal of notice requirement: The permittee submitted notice to DAQ, in a letter dated 11/17/06, that replacement of the baghouse on the referenced emission unit is not going to occur as described in DAQE-AN03030 11-05, dated 5/20/05. The permittee’s NOI for the redesigned project is currently in process. The notification requirement has been removed from the permit. [Comment last updated on 11/28/2006]

9. Comment on an item originating in DAQE-AN0303011-05 regarding West Clinker Belt (Unit 419.BF5) Removal of notice requirement: The permittee submitted notice to DAQ, in a letter dated 11/17/06, that replacement of the baghouse on the referenced emission unit is not going to occur as described in DAQE-AN03030 11-05, dated 5/20/05. The permittee’s NOI for the redesigned project is currently in process. The notification requirement has been removed from the permit. [Comment last updated on 11/28/2006]

10. Comment on an item originating in this permit regarding optical density in the CAM plans [Comment last updated on 11/2/2006]

Sample optical density calculations for informational purposes:

Optical density relates to opacity through the following equation.



## ( ) ⎟ ⎟ ⎠ ⎞ ⎜ ⎜ ⎝ ⎛

− = ⎟ ⎠ ⎞ ⎜ ⎝ ⎛

= Opacity T OD 1 1 log 1 log

Where: OD = Optical density T = Transmittance or (1 – Opacity), with opacity in decimal form

Sample calculations for optical density:

Issued December 1, 2006 Page 56 Title V Operating Permit #2300015002Given a measured opacity of 9.1%, optical density becomes,



### 041.0 091.01 1 log = ⎟ ⎠ ⎞ ⎜ ⎝ ⎛

− = OD

Given a measured opacity of 10%, optical density becomes,



### 046.0 10.01 1 log = ⎟ ⎠ ⎞ ⎜ ⎝ ⎛

− = OD

Additional information can be found in the EPA Handbook, “Continuous Emission Monitoring Systems for Non-criteria Pollutants” EPA/625/R-97/001 August 1997, pgs

43-47.

Issued December 1, 2006 Page 57 Title V Operating Permit #2300015002